South Africa's National Gambling Board (NGB) is shopping for a contractor to do something the law has never explicitly told anyone it may do: block websites nationwide. An amended Expression of Interest, first issued 30 June 2026, seeks a provider to monitor, profile, block and continuously re-block illegal offshore gambling platforms targeting South African consumers. The deadline, pushed back from 7 August, now closes 4 September 2026, following a briefing session for bidders held on 15 July (NGB erratum; iGaming Business).
A Real Problem, Honestly Stated
The scale of the issue is not manufactured. Research commissioned by the South African Bookmakers' Association from Yield Sec found illegal operators accounted for roughly 62% of all online gambling activity in the country, diverting more than R50 billion in gross gambling revenue offshore annually, with an estimated 16 million South Africans having used these platforms in the past year (SABA/Yield Sec, via Bookies.co.za). That is lost tax revenue, unregulated consumer protection, and a wide-open channel for problem gambling. The NGB's acting CEO, Lungile Dukwana, has also been candid about the limits of the tools regulators currently rely on: sites flagged to Google and Meta for takedown reappear "the following day with something else," which is why the new EOI builds in a continuous tracking function to re-block sites that resurface under new domains (FocusGN). A regulator that admits its own remedy is a treadmill deserves credit for candour, if not yet for a working plan.
The Legal Gap ISPA Is Pointing At
The Internet Service Providers' Association (ISPA) is not arguing that illegal gambling should go unaddressed. Its position paper, published 2 July 2026, explicitly accepts that some blocking "may be necessary" — the fight is over who orders it and under what authority. ISPA's chair, Sasha Booth-Beharilal, put it plainly: "any disruption of internet services to South Africans should be done only as part of a clear legislative framework that balances the right to communicate against potential harm" (TechCentral). That framework does not currently exist. The National Gambling Amendment Bill (B27-2018), which would have repositioned the NGB as a National Gambling Regulator with expanded powers, was rejected by the National Council of Provinces and sent to a Mediation Committee, which reported back in June 2025 — it remains unpassed (Parliament of South Africa). The NGB is, in effect, asking the Department of Communications and Digital Technologies to authorise a national blocking regime administratively, in the absence of the statute that was supposed to give it this authority in the first place.
That sequencing matters. Site-blocking is a restriction on access to information and communication — a fact South African courts have taken seriously in other contexts, and one ISPA's paper leans on directly by proposing blocking should be court-ordered rather than administratively imposed, publicly disclosed, time-limited and subject to periodic review, achievable without forcing ISPs to re-engineer their networks, and funded through fair cost allocation rather than dumped on providers by decree.
Blocking Technology Doesn't Do What Regulators Hope
ISPA's technical objections are where the NGB's plan runs into physics, not just law. Domain-name blocking is trivial to defeat with a VPN or an alternative DNS resolver — which is precisely why Dukwana's own account of Google/Meta takedowns describes a game of whack-a-mole. IP-address blocking is worse in a different way: because so many websites share IP addresses on modern cloud infrastructure, blocking one address routinely takes down unrelated, entirely legal sites. ISPA cites an OONI (Open Observatory of Network Interference) report on a European case where a court-ordered block of a handful of shared IP addresses inadvertently took down more than half a million unrelated websites (IT-Online). Deep packet inspection, the most thorough method, is also the most invasive — the kind of always-on traffic surveillance infrastructure normally associated with authoritarian internet control, and still defeated by a VPN.
Why the Steelman Doesn't Rescue the Plan
There is a coherent case for narrow, court-supervised blocking as one tool among several — the UK's approach to unlicensed gambling sites and India's judicial blocking orders under IT Rules both show it can be done with due process attached. But South Africa's NGB is trying to build the enforcement infrastructure before the legislature has decided whether, and how, it may be used. That inverts the correct order of operations for any measure that restricts access to lawful communications infrastructure for millions of users to catch a comparatively small and endlessly mobile set of bad actors. A procurement contract cannot substitute for a statute, and a blocking system built on administrative say-so — however well-intentioned — sets a precedent that will outlive this specific problem, available to the next regulator with a different target list. If NGB and DCDT want blocking powers, the honest route runs through Parliament finishing the Gambling Amendment Bill or passing bespoke enabling legislation with ISPA's five safeguards built in, not through an EOI that treats a still-open legal question as already settled.