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Taking a deeper look at these restrictive driving black market activity, up to 46% of the markets covered in the report enforced “significant advertising restrictions” on the regulated market, including in Belgium, Bulgaria, Coratia, Cyprus, Germany, Italy, Latvia, Lithuania, Montenegro, the Netherlands, Poland, Romania and Spain.

Additionally the report cited taxing consumers (in 29% of the 28 markets covered), and banned products (14%), were also propelling growth in illegal gambling. A lack of choice, due to monopolies in place in five markets has also driven the rise.

Players typically play across various verticals, and by imposing restrictions on specific verticals or betting markets, engaged customers will look elsewhere to access these activities.

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Kemorwale said Botswana needed to modernise oversight as the sector developed, including through a central electronic monitoring system and stronger enforcement capability. “Truth be told, this industry is evolving as the sun rises. You snooze, you lose,” Kemorwale said. He added that the Authority still relies on outside specialists for some technical regulatory work because domestic expertise is limited.

Illegal betting remained a central enforcement concern. In December 2025, the Gambling Authority and Financial Intelligence Agency were reported to be investigating eight foreign-based betting websites allegedly using local proxies to operate in Botswana.

Authorities were also reported to be working with communications and financial-sector bodies to restrict access to illegal platforms and disrupt associated payment channels.

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“Our role as a regulator is not to stand in the way of innovation, but to help create the certainty and confidence needed for innovation to flourish responsibly,” Mizzi said.

The charter does not create new regulatory obligations and was designed to complement legislation including the EU AI Act and GDPR.

Instead, it proposed a risk-based approach. It suggested lighter controls on use cases such as coding assistants, but strong checks on customer-facing functions, particularly those involving fraud and responsible gambling.