Poland and France cooperation on grey market information

Poland and France have taken a significant step toward strengthening cross-border oversight of gambling activity by signing a new cooperation agreement focused on the exchange of information related to the grey market. The agreement represents a coordinated effort by two European Union member states to enhance the legal, regulatory, and operational tools available for combating unlicensed gambling activity, particularly as such activities increasingly involve international operators and financial channels.

The initiative aligns with ongoing efforts across Europe to safeguard players, support regulatory transparency, and ensure that national markets operate within established legal frameworks. Although the full text of the agreement has not yet been publicly released, available information indicates that both countries intend to share relevant data concerning financial flows and illegal operators, which are commonly viewed as key components of the broader grey-market ecosystem.

Background and relevance of cross-border collaboration

As gambling services continue to evolve and expand across digital platforms, national regulators have encountered growing complexity in addressing unlicensed domestic and offshore operators. Many such operators rely on international payment systems, foreign-registered domains, and cross-border advertising networks. These elements make unilateral enforcement efforts more difficult for national regulators, particularly when the operators in question are located outside the country where the activity is accessed.

By developing formal cooperation channels, regulatory authorities are better positioned to exchange technical, financial, and operational information. This includes patterns of fund movement, identification of offshore entities, and the detection of promotional or technological systems that may target local players without authorization.

The agreement between Poland and France appears designed to support these broader objectives and facilitate a more informed regulatory environment in both jurisdictions.

Scope of cooperation between the two countries

Exchange of information on the grey market

According to information obtained by industry observers, the cooperation is expected to include the coordinated exchange of data related to the grey market. This may involve strategic, non-public information that could help each country identify unlicensed operators and their methods of accessing national markets. While specific mechanisms have not yet been disclosed, such cooperation typically includes regulatory intelligence, risk assessments, and technical data concerning online domains or platforms linked to unlicensed activity.

Monitoring of financial flows

The agreement is also expected to enable closer oversight of financial flows connected with unauthorized gambling operations. Grey-market operators frequently use payment intermediaries, alternative financial technology channels, or foreign bank accounts to receive player funds. Monitoring these flows may assist regulators in determining whether certain activities violate national laws or pose risks to consumers, such as the absence of responsible gambling protections, ineffective verification systems, or a lack of recourse for players.

Identification of illegal operators

The cooperation may further support efforts to identify operators that intentionally target players in regulated jurisdictions without required authorization. This could include identifying operators that use foreign domains, mirror websites, or indirect advertising in order to circumvent national restrictions. Cross-border recognition of such operators may enable enforcement actions when permissible under national legislation, such as requests for domain blocking, payment blocking, or administrative sanctions.

Legal frameworks in France and Poland

Situation in France

France maintains a highly controlled regulatory environment for gambling services. As currently structured, France is, alongside Cyprus, one of only two EU member states that fully prohibit online casino services. This prohibition reflects France’s legal approach to limiting online gambling activity to clearly defined, regulated sectors.

According to data reported by the French regulatory authority, Autorité Nationale des Jeux (ANJ), approximately three million players in France used offshore or unlicensed online services in 2023. These figures illustrate the scale of demand for online casino-type products that are not legally offered within the country. The prevalence of unlicensed platforms also highlights the challenges faced by regulators seeking to limit unauthorized market activity.

Within the legal framework, France permits only specific categories of gambling. These include:

• licensed sports betting operators registered with ANJ,
• land-based casinos operating under domestic authorization,
• Pari Mutuel Urbain (PMU), which manages the country’s regulated horse-racing betting system, and
• the national lottery through the French Loto.

This structure places online casino games outside the scope of permissible digital gambling activities. As a result, a substantial portion of the demand has shifted toward offshore sites, contributing to identifiable grey-market activity.

Situation in Poland

Poland also maintains a highly restrictive legal regime for online casino gambling. Under Polish law, Total Casino, operated by Totalizator Sportowy—the state lottery operator—is the only legally authorized online casino platform in the country. Outside this single state-approved entity, no other operator may legally provide online casino games in Poland.

According to available estimates circulated within industry analyses, the Polish grey market may have generated turnover exceeding PLN 60 billion in 2024, which is approximately €13–14 billion. These figures underscore the significant market share captured by unlicensed operators and the scale of economic activity occurring outside Poland’s regulated gambling framework.

Restrictive licensing policies and strong market demand often create incentives for offshore platforms to target domestic players without the necessary authorization. These dynamics contribute to regulatory challenges, including incomplete tax collection, reduced consumer protection, and risks associated with unverified payment systems.

Importance of the agreement for both countries

Enhancing transparency and accountability

By establishing a formal pathway for regulatory cooperation, the agreement creates an opportunity to improve transparency in critical areas of market oversight. This includes sharing knowledge about new technological methods used by operators to evade restrictions, monitoring of international financial transactions, and analysis of consumer behavior trends that may indicate exposure to unlicensed platforms.

Supporting consumer protection

Consumer protection remains a primary concern for both countries, particularly as grey-market operations are not subject to the same safeguards imposed on licensed platforms. These safeguards typically include responsible gambling programs, age verification, anti-money-laundering requirements, and mechanisms for handling disputes. Enhanced cooperation may facilitate earlier detection of practices that could place consumers at risk.

Strengthening enforcement capabilities

While neither country can take enforcement action outside its own jurisdiction unless permitted through established legal procedures, access to reliable information may support domestic enforcement measures. For example, regulators might request payment service providers to restrict transactions linked to certain operators, or they may add foreign domains to national blocking lists where legally permissible.

Supporting EU-wide regulatory stability

Although each EU member state retains the authority to regulate gambling independently, international cooperation contributes to a more consistent legal environment. This agreement between Poland and France could serve as a reference point for future bilateral or multilateral arrangements among other European regulators seeking to address shared challenges.

Potential implications for the European market

Increased scrutiny of cross-border operations

The agreement may encourage operators to conduct thorough reviews of their practices to ensure compliance with relevant national laws. Grey-market platforms frequently rely on legal uncertainty or jurisdictional complexity; increased cooperation reduces these ambiguities by strengthening the information environment available to regulators.

Possible influence on future legislation

Enhanced data exchange between countries often reveals patterns or trends that may prompt legislative review. Policymakers may consider whether additional regulatory approaches are needed to address identified risks or to modernize existing frameworks in alignment with technological developments.

Impact on consumer behavior

If enforcement activity intensifies as a result of improved information sharing, consumer access to unlicensed websites may be limited over time. This may encourage a shift toward safer, regulated alternatives, provided those alternatives meet player expectations regarding entertainment options and accessibility.

Conclusion

The agreement between Poland and France to exchange information related to grey-market gambling activity represents a proactive step toward enhancing regulatory cooperation in an area characterized by growing complexity and international interconnection. While details of the framework are still forthcoming, the initiative reflects an increasing recognition across Europe of the importance of coordinated oversight in protecting consumers, strengthening legal compliance, and maintaining the integrity of national gambling markets.

The outcome of this cooperation will likely depend on the practical mechanisms put in place, the quality of exchanged information, and the ability of each country to implement appropriate domestic measures based on shared insights. Nonetheless, the agreement signals a constructive direction for future collaboration and could set a precedent for additional cross-border partnerships within the European regulatory landscape.

FAQs

What is the main purpose of the Poland-France agreement?
The agreement aims to facilitate the exchange of information related to grey-market gambling activities, including data on financial flows and unlicensed operators.

Why is cooperation important in regulating gambling markets?
Cross-border cooperation helps regulators address activities that span multiple jurisdictions, enabling better oversight and more effective enforcement within national laws.

Does the agreement change gambling laws in either country?
No, the agreement does not alter the legal frameworks of Poland or France; it focuses on enhancing information sharing and regulatory cooperation.

Why is online casino gambling prohibited in France?
French law restricts digital gambling to specifically designated categories. Online casino games fall outside these authorized categories.

How large is the grey market in Poland?
Estimates suggest that the grey market in Poland may have generated over PLN 60 billion in turnover in 2024, indicating substantial unlicensed activity.

What legal gambling options exist in France?
France permits licensed sports betting, land-based casinos, PMU horse-racing bets, and the national lottery, but does not authorize online casinos.

Is Total Casino the only legal online casino in Poland?
Yes, Total Casino, operated by Totalizator Sportowy, is the sole legal online casino under Polish law.

Does the agreement target specific companies?
No specific companies have been named. The agreement focuses on general regulatory cooperation within the confines of applicable law.

Will players notice immediate effects of this agreement?
Any effects will likely occur gradually as cooperation supports regulatory actions, consumer protection measures, and enforcement activities.

Could similar agreements appear elsewhere in Europe?
Yes, this initiative may encourage other EU member states to establish their own cooperative arrangements to address cross-border gambling concerns.