Regulating gambling in France in the digital age: from casinos to Web3

Summary

• A growing market under regulatory strain: France’s gambling market reached record levels in 2025 yet remains constrained by a distinctive regulatory model that prohibits online casinos and struggles to contain large‑scale illegal gambling.
• Digital innovation as a partial regulatory workaround: France’s response to digital disruption has focused on Web3 gaming through the “JONUM” regime, inspired by the Sorare business model; while designed as an innovation‑friendly framework, it has progressively incorporated safeguards drawn from traditional gambling regulation notably on financial crime prevention, youth protection and addiction prevention.
• A shift toward consumer‑facing regulation in Europe: Beyond market access, European gambling policies increasingly target advertising exposure, through a variety of developments such as advertising restrictions and tighter marketing restrictions, developments that France could now consider as potential regulatory models.

Introduction

As IMGL members prepare to travel to Paris for the 2026 Autumn Conference, this article is a perfect primer of the market they will encounter. The French gambling market reached an unprecedented level of activity in 2025, with gross gaming revenue approaching €14,1 billion according to the most recent market reviews published by the French National Gaming Authority (“Autorité nationale des jeux”, “ANJ”)[1]. This represented a 3 percent growth since 2024 and has been driven primarily by online gambling, lottery products operated under a monopoly, and land‑based casinos.

This expansion takes place within a regulatory framework that remains distinctive at the European level. In 2022, the country hosted 202 land‑based casinos, half of which were independently operated[2]. According to the French Court of Auditors, these establishments accounted for approximately 32 percent of the entire European casino stock, reflecting a historically dense and territorially embedded model[3].

This exceptional footprint is closely linked to local economic development, employment, and tourism strategies, particularly in mid‑sized municipalities. The strong political influence of the land‑based casino sector helps explain France’s sustained reluctance to permit online casino gambling, even as most EU Member States have liberalized this segment under national licensing regimes.

The difficult question of legalization of online casinos

Against this background, the question of online casino legalization periodically resurfaces in French policy debates. While online activity represents a minority share of total gross gaming revenue, it remains the fastest‑growing segment, specifically in sports betting[4]. Expectations briefly rose in recent years that France might follow neighbouring jurisdictions, notably after the government announced a stakeholder consultation in November 2024.

However, the ANJ has adopted a cautious position, highlighting the significant public‑health risks associated with online casinos and underlining their potentially highly addictive nature. This notwithstanding, it has indicated that it would contribute to the development of a coherent, robust and safe legislative framework should the decision to legalize online casinos ultimately be taken[5]. In the recent French political context marked by parliamentary fragmentation and heightened sensitivity to social and health‑related concerns, such reform appears increasingly unlikely in the near term.

Meanwhile, illegal online casinos continue to expand rapidly, capturing a demand that exists regardless of the legal framework. According to estimates by the ANJ for 2023, between three and four million players engage in online casino gambling through illegal platforms[6], generating annual player losses estimated at between €748 million and €1.5 billion which represents between 5 and 11 percent of the French global gambling market[7].

Advocates of reform argue that online casinos already constitute a significant and economically dynamic sector operating outside regulatory oversight, and that the establishment of a dedicated legislative framework could help channel this activity into a controlled, responsible and secure legal offer. Under such a regime, licensed operators would be required to implement strict safeguards, including robust age‑verification systems, spending and time limits, and enhanced tools for the prevention and detection of problematic gambling behaviour, thereby strengthening player protection through regulatory supervision rather than prohibition.

Some argue that opening the way to legal online casino would help reduce illegal gambling. Whereas today, although the ANJ holds strengthened enforcement powers, its operational resources appear likely to be insufficient to significantly curb illegal supply, particularly where operators are based outside EU jurisdiction. Since 2022, the ANJ has had the power to initiate actions to administratively block and delist illegal gambling sites[8]. Yet, such procedures must go through formal notices with a five-day delay for the operator to present its observations. Furthermore, the ANJ cannot effectively prevent the rapid reappearance of “mirror sites” by which the illegal operator creates carbon copies of the original site just with another URL address. When the illegal online gambling operator is established abroad, French decisions struggle to be enforced. Yet, such a decision will remain fully enforceable in France, meaning that any return of the illegal operator’s financial profits to French soil will be considered as money laundering, hence criminally sanctioned.

Of course, analysis of the current legislative frameworks across European countries shows that online casino legalization does not fully eliminate illegal gambling. In most jurisdictions, a residual share of illegal supply persists. In particular, legalization will not unravel the complexity of enforcement that the national regulator faces with international operators. However, experience has shown that a trustable, visible, commercially attractive, legal gambling option will be favoured by most consumers, as was the case for the music and audiovisual industries. As a result, legalization appears the most efficient option to tackle illegal online gambling.

An alternative route? Web3 games regulation

France now stands as the last major EU gambling market not to have introduced a legal online casino framework. In the meantime, France chose to direct its regulatory efforts toward a different opportunity: Web3‑based gaming, closely linked to the emergence of the French unicorn Sorare. Sorare’s business model is built on blockchain technology and centres on the issuance and exchange of officially licensed digital player cards in the form of NFTs, which users acquire either through primary sales or on a secondary market. These digital assets are then used to compose fantasy teams whose performance depends on real‑world sporting results, introducing elements of competition, skill, and uncertainty without formally relying on monetary wagering. This hybrid model combining collectibles, gameplay mechanics and market‑based valuation has challenged traditional regulatory categories situated between gaming, gambling and digital asset trading.

In response to these developments, France has created a distinctive intermediate regulatory framework for Web3 games, separate from conventional gambling law, with the objective of accommodating innovative business models based on transferable digital assets while preserving regulatory control. The introduction of the “games with monetizable digital objects” (JONUM) regime under the 2024 SREN law[9] thus reflects an attempt to address emerging digital practices without fully assimilating them into the legal framework governing gambling.

Designed initially to promote innovation and legal certainty while avoiding the immediate application of gambling prohibitions, the JONUM regime establishes an intermediate legal status for games incorporating tradable digital tokens, particularly within Web3 environments. Although its legislative foundations were adopted nearly two years earlier, the regime only became fully operational in February 2026, following the publication of the implementing decrees and orders that completed the regulatory framework[10].

While conceived as a and innovation‑friendly, the JONUM regime has progressively been drawn into the orbit of gambling law. Obligations relating to anti‑money laundering and counter‑terrorist financing (AML/CFT), protection of minors, and addiction prevention now apply, significantly aligning the JONUM framework with the core requirements of gambling regulation. One of the main areas of divergence remains that such games are not subject to the granting of a licence. They require a “simple” notification to ANJ which is then responsible for monitoring the compliance of the operator with its regulatory obligations.

This progressive convergence should not be understood as a regulatory accident, but rather as the result of structural risk factors inherent to monetizable digital games. As digital assets may be acquired, exchanged, and generate financial exposure for users, regulators are inevitably led to mobilise the core instruments of gambling law in order to address risks related to money laundering, youth exposure and problematic gambling behaviour. In this sense, the JONUM regime illustrates less a distinct regulatory category than a controlled entry point into the broader gambling regulatory framework.

However, the uncertain trajectory of Web3 gaming markets raises open questions as to whether this regime will foster sustained industry development or remain a niche regulatory response to a limited set of use cases, especially at a time when interest in Web3 gaming has declined. Beyond its original objectives, the JONUM regime might theoretically evolve into an extensive alternative regulatory model, including potentially for crypto‑casino‑type offerings.

Increased constraints for online operators marketing strategies

More broadly, recent regulatory developments illustrate a shift in focus across Europe from the organization of gambling markets towards mechanisms by which gambling demand is stimulated, particularly through marketing and advertising. From this perspective, major international sporting events function as regulatory stress tests, amplifying concerns linked to visibility, normalisation of gambling behaviour and youth exposure across multiple jurisdictions simultaneously.

France now displays an evolving approach to sports betting advertising in light of the 2026 FIFA World Cup. Through enhanced monitoring, targeted recommendations and increased scrutiny of operators’ marketing strategies, the ANJ increasingly aims to limit excessive promotional pressure, reflecting a shared understanding that player protection cannot rely solely on licensing regimes. In this context, the ANJ has actively encouraged the adoption of a “whistle‑to‑whistle” ban[11], similar to the model implemented in the United Kingdom, which prohibits gambling advertising during live sports broadcasts from the start to the end of a match. That said, the French National Assembly has declined to include such a proposal in the bill on the organisation of professional sport currently under consideration[12]. Although studies show the English whistle-to-whistle ban has had a tangible effect on reducing the visibility of betting products during live sport broadcasts[13] and on children’s exposure to gambling advertising[14], members of the National Assembly considered such measure would be detrimental to the French sports sector. In their view, it would reduce commercial revenues without preventing viewers from being exposed to advertisements for illegal gambling operators during broadcasts of sporting events held abroad. At the same time, recent developments in the United Kingdom indicate that the limits of self-regulation are themselves coming under scrutiny, as the UK All-Party Parliamentary Group on Gambling Reform considers stronger statutory controls on sports betting marketing[15].

Comparable regulatory logics can also be observed in the Nordic countries, where gambling regulation has progressively enhanced consumer protection measures. Norway has prohibited television advertising of gambling in 2022. Denmark has restricted time slots, the use of celebrities and marketing bonuses since 2022[16]. If gambling regulation remains a national competence, regulatory convergence occurs through shared public‑health objectives rather than formal harmonization, gradually reshaping operator conduct across borders.

Unbearable tax pressure

Finally, fiscal policy adds an additional layer of complexity to the French regulatory model. While certain aspects of gambling taxation were partially harmonised at the European level in 2019, significant disparities persist between online and land‑based offerings. In France, taxation remains markedly heavier for online betting activities than for terrestrial operations[17].

When combined with increasingly restrictive advertising rules and heightened compliance obligations, this fiscal imbalance places the regulated online offer under growing pressure. Licensed operators face rising costs and limited commercial flexibility at a time when illegal platforms continue to benefit from both regulatory and fiscal arbitrage. This asymmetry risks undermining one of the core objectives of gambling regulation, namely, the effective channelisation of demand toward a controlled and protective legal market. The long‑term challenge for France therefore lies not only in defining where to draw the legal boundaries of gambling, but also in ensuring that regulatory tools remain proportionate, coherent and capable of competing with an increasingly sophisticated illegal market.

[1] ANJ in Bilan 2025 du marché des jeux d’argent : une progression portée par le marché en ligne, la loterie et les casinos | ANJ

[2] French Court of Auditors (Cour des comptes) in Rapport public thématique, Les jeux d’argent et de hasard : un secteur en mutation, des enjeux de régulation, 21 september 2023

[3] French Court of Auditors (Cour des comptes) in Rapport public thématique, Les jeux d’argent et de hasard : un secteur en mutation, des enjeux de régulation, 21 september 2023

[4] French Court of Auditors (Cour des comptes) in Rapport public thématique, Les jeux d’argent et de hasard : un secteur en mutation, des enjeux de régulation, 21 september 2023

[5] ANJ Annual Report 2024

[6] PwC Report on illegal online offers requested by ANJ, 15 December 2023

[7] ANJ Annual Report 2024 referring to PwC Report on illegal online offers requested by ANJ, 15 December 2023

[8] Article 49 of law n° 2022-296, 2 March 2022

[9] Articles 40 and 41 of SREN law n° 2024-449, 21 May 2024

[10] Decree n° 2026-60 of 4 February and Order of 4 February 2026

[11] ANJ in Publicité pour les paris sportifs pendant la Coupe du Monde de football 2026 : l’ANJ appelle l’ensemble des acteurs à modérer la pression publicitaire | ANJ

[12] French National Assembly Commission report n°2797

[13] McGrane, E., Pryce, R., Wilson, L., Field, M., & Goyder, E. (2024). How did the ‘whistle-to-whistle’ ban affect gambling advertising on TV? A live football matching study. Addiction research & theory, 33(2), 134–142. https://doi.org/10.1080/16066359.2024.2355183

[14] UK Policy Paper, High Stakes: Gambling Reform for the Digital Age, 27 April 2023 : Advertising Standards Authority (ASA) data shows that the average number of sports betting adverts seen by children under 16 fell from 0.7 to 0.3 per week between 2018 and 2019.

[15] Gambling Advertising, Marketing and Sponsorship: Recommendations for the reform report by the All-Party Parliamentary Group on Gambling Reform (Gambling Reform APPG) & Peers, 23 April 2026

[16] Marionneau V, Lindeman M, Cisneros Örnberg J, Karlsson T. From Policy to Politics: Is there a Nordic Model for the regulation of alcohol and gambling?, 1 July 2025

[17] French Court of Auditors (Cour des comptes) in Rapport public thématique, Les jeux d’argent et de hasard : un secteur en mutation, des enjeux de régulation, 21 September 2023

Diane Mullenex and Annabelle Richard are Partners in Pinsent Masons Retail, Sport & Leisure group based respectively in London and Paris