For associations

Your members lose players to sites that pay no tax and hold no licence. What they can put in front of a regulator is a channelling estimate, and an estimate is arguable by anyone who dislikes the conclusion.

The leakage is measurable at the payment layer, because an unlicensed site still has to be banked by somebody. Nowhere in the market is anyone measuring it there.

No single member can do the measuring. Buying from a competitor is a conflict, and being seen to do it is a headline; the work has to sit outside every member's own house.

That leaves advocacy resting on modelled numbers at exactly the moment the argument turns to enforcement, where a named payment route would settle it.

Sector-wide measurement of the unlicensed share of a market taken at the payment layer, refreshed across a collection programme rather than sampled once.

Evidence a member can hand to its regulator without having generated it, and without any member being identifiable as the party that commissioned a given collection.

A shared evidence pool: the cost of a programme sits with the association, and every member reads the same findings on the same day.