Belgium’s Federal Public Service (SPF) Economie has taken an unprecedented step against two of the world’s largest internet infrastructure companies, ordering Google and Cloudflare to block access to 49 unauthorised gambling websites operating outside the country’s regulatory framework. The injunction shifts enforcement pressure away from individual site operators and onto the DNS and CDN providers that, in the regulator’s framing, technically facilitate access to unlicensed platforms. It is the first time a European authority has pursued this particular enforcement pathway against intermediaries of this scale in the gambling sector. The action establishes a legal template that other EU member states are almost certainly watching.
What Belgium’s Intermediary Enforcement Strategy Signals for the Industry
Before diving into the specifics, it’s worth understanding what makes this case structurally different from previous blocking orders across Europe. Regulators in Italy, the Netherlands, and parts of Scandinavia have long maintained blocklists targeting unauthorised gambling domains. But those orders typically landed on internet service providers (ISPs), not on upstream infrastructure companies like DNS resolvers and content delivery networks. Belgium’s approach targets a deeper layer of the internet stack.
- Intermediary liability is expanding: By holding Google (as a public DNS resolver) and Cloudflare (as both a DNS and CDN provider) accountable, Belgium is redefining who bears responsibility for enabling access to unlicensed gambling operations
- 49 domains blocked in a single action: The scope of the injunction covers a substantial number of sites, suggesting coordinated intelligence-gathering by the SPF Economie rather than piecemeal enforcement
- The legal basis draws on existing frameworks around online piracy and intellectual property sanctions, repurposed for gambling enforcement
- Precedent risk for tech providers: If upheld and replicated, this model could force infrastructure companies to build compliance mechanisms for gambling regulation across multiple jurisdictions simultaneously
- Operator-level enforcement hasn’t disappeared — but Belgium is clearly signalling that going after the pipes, not just the taps, is now part of the toolkit
Why DNS and CDN Blocking Cuts Deeper Than ISP-Level Restrictions
Traditional ISP blocking is, in practice, a blunt instrument. Users with even modest technical knowledge can circumvent it by switching to a public DNS resolver like Google’s 8.8.8.8 or Cloudflare’s widely used 1.1.1.1 service. That workaround is precisely what makes Belgium’s new approach more consequential. When the resolver itself is ordered to block a domain, the circumvention path narrows considerably.
CDN-level blocking adds another dimension. Cloudflare doesn’t just resolve domain queries; it caches and delivers website content from edge servers distributed globally. Stripping a site from Cloudflare’s network degrades its performance, reliability, and in some cases its ability to function at all. For operators running unauthorised gambling platforms on thin margins and borrowed infrastructure, losing CDN support can be operationally fatal.
Still, technical limitations persist. Determined operators can migrate to alternative providers, deploy their own DNS infrastructure, or route through jurisdictions where Belgian orders carry no weight. Whether this enforcement model proves durable depends on how quickly operators adapt and whether Belgium pursues follow-up actions against successor domains.
The Legal Architecture Behind the Injunction
What’s particularly striking is the legal foundation Belgium chose. Rather than crafting new gambling-specific legislation for intermediary liability, the SPF Economie drew on existing provisions related to online piracy and intellectual property enforcement. That framework already established the principle that intermediaries can be compelled to act against unlawful content they transmit or host, even when they are not the primary infringers.
Repurposing IP enforcement mechanisms for gambling regulation is a creative legal manoeuvre (a distinction that may not survive challenge in every jurisdiction). It sidesteps the slow process of drafting new legislation while leveraging case law and procedural norms that courts and companies already understand. Google and Cloudflare have both faced similar orders in copyright contexts across Europe, which arguably makes the compliance burden less novel than it might appear.
Whether either company contests the order remains to be seen. Google’s public DNS infrastructure serves hundreds of millions of users globally, and accepting jurisdiction-specific blocking obligations at this layer raises questions about scalability and fragmentation of the open internet.
How Other European Regulators Might Respond
Belgium’s action doesn’t exist in a vacuum. Across the EU, gambling regulators have been tightening enforcement against unlicensed operators, but most have relied on ISP blocking, payment processing restrictions, and advertising bans. The intermediary model Belgium is pioneering opens a fourth front.
| Enforcement Method | Common In | Effectiveness | Circumvention Difficulty |
|---|---|---|---|
| ISP-level DNS blocking | Italy, Netherlands, Sweden | Moderate | Low — users switch DNS resolvers |
| Payment processor blocking | UK, France, Germany | High for fiat transactions | Moderate — crypto alternatives exist |
| Advertising and affiliate bans | Most EU markets | Variable | Low — offshore affiliates persist |
| DNS resolver and CDN blocking (Belgium model) | Belgium (first mover) | Potentially high | Higher than ISP blocking, but not absolute |
The Belgian precedent gives other regulators a tested legal pathway. Italy’s AGCOM, which already operates one of Europe’s most aggressive blocklists, could be an early adopter. And the European Commission’s ongoing work on the Digital Services Act creates a broader regulatory environment where intermediary obligations are expanding across content categories.
Reframing Compliance: What Infrastructure Providers Face Next
For companies like Google and Cloudflare, this case forces a strategic reckoning. Both have historically positioned themselves as neutral conduits, arguing that they neither control nor endorse the content flowing through their networks. Belgium’s injunction challenges that framing directly, treating infrastructure provision as a form of facilitation when the content is demonstrably unlawful under national law.
The compliance implications ripple outward. If Belgium’s model gains traction, infrastructure providers may need to build jurisdiction-aware filtering systems capable of responding to regulatory orders from dozens of national authorities, each with different definitions of what constitutes an unauthorised gambling operation. That’s an engineering challenge, a legal challenge, and a business model challenge all at once.
And the gambling industry isn’t the only sector watching. Crypto exchanges, unlicensed financial service platforms, and content providers operating in regulatory grey zones all rely on the same infrastructure stack. The principle Belgium is asserting here, that intermediaries share responsibility for the lawfulness of what they enable, has implications that extend well beyond betting.
Frequently Asked Questions
What exactly did Belgium order Google and Cloudflare to do?
The Belgian Federal Public Service Economie issued an injunction requiring both companies to block DNS resolution and, in Cloudflare’s case, CDN services for 49 specific gambling websites operating without Belgian authorisation. The order treats these companies as technical facilitators of unlicensed gambling activity.
Is this the first time a European country has targeted DNS providers for gambling enforcement?
At this scale and specificity, yes. Previous European blocking orders in the gambling context have primarily targeted ISPs. Belgium’s decision to go after upstream infrastructure providers like public DNS resolvers and CDN networks represents a materially different enforcement approach.
Can users still access the blocked sites?
Technically sophisticated users may find workarounds, including alternative DNS resolvers not subject to the Belgian order or VPN services routing through other jurisdictions. But for the majority of casual users, the blocking will be effective. The enforcement model doesn’t claim to be airtight; it aims to reduce accessibility at scale.
Could other countries replicate this approach?
The legal framework Belgium used, rooted in existing intellectual property and online piracy provisions, exists in comparable forms across multiple EU member states. Replication is plausible, though each jurisdiction would need to test the approach against its own legal standards and potentially face challenges from the affected companies.
