MEF CEO Dario Betti takes a look at recent developments in the German regulatory landscape for online gambling, as regulators attempt to tackle the pervasive illegal online gambling sites which are preventing the legal market from flourishing as they have elsewhere in Europe.
The German online gambling market has faced significant regulatory challenges despite recent efforts to establish a more controlled and legalized framework. In Germany, 2024 has seen a new regulatory focus, with greater powers given to the GGL (Gemeinsame Glücksspielbehörde der Länder) authority. However, the impact of illegal online gambling operations remains substantial.
Expansion of GGL’s Powers and Enforcement Challenges
Since January 2024, the GGL has strengthened its regulatory powers and taken more aggressive steps against unlicensed operators. While the GGL has expanded its tools to combat illegal gambling—including prohibition orders and improved collaboration with licensed operators—Germany’s black market for online gambling remains pervasive. This market has seen illegal operators resisting regulation due to both gaps in enforcement and the continued appeal of unregulated sites.
The potential for growth in Germany’s online gambling market remains significant, but the development and maturation of its legal framework will be essential.”
Licensing Procedures and Restrictions
The German Interstate Treaty on Gambling (ISTG 2021) was a welcome piece of legislation that laid the groundwork for a legal online gambling market.
Licenses for online sports betting, virtual slot machines, and poker have been streamlined under the GGL, but the limitations on offerings have hindered market growth. In particular, the fragmented licensing process for online casino games—still controlled by individual Federal States—leaves major gaps in the system.
Moreover, restrictions on advertising, betting market rules, and the slow approval processes for new games have limited the activities of legal operators while unlicensed platforms continue to thrive.
Market Underperformance and Illegal Operators
Germany’s legal online gambling market remains underdeveloped compared to its European counterparts, despite the country’s large population. With a reported turnover of €4.8 billion in 2023, the legal market significantly lags the UK’s €12.05 billion (data from iGB). According to the GGL, methods to prevent illegal players, such as payment and IP blocking, were used for the first time in 2023, along with threats of fines and legal action. Nevertheless, German courts remain unclear on whether IP blocking is allowed under German law. Illegal operators are more commonly identified through players’ direct reports to hotlines.
According to 2023 figures from the GGL, between 800 and 900 websites offered illegal online gambling in Germany, accounting for approximately €500 million in consumer spending—around 10% of the authorized market.
Few criminal cases have made it to court, which is not surprising given the recent implementation of the regulatory framework. However, online gambling industry associations are calling for a much stronger response, as they believe illegal operations account for a significantly larger share of the market, limiting the growth of new approved operators. Research commissioned by the German Online Casino Association (DOCV) and the German Sports Betting Association (DSWV) suggests that illegal gambling still holds around 47% of the total market, with approximately 1,380 unauthorized websites actively targeting German players.
Outlook for the German Online Gambling Market
The current regulatory framework is expected to remain in place until 2027; hence, meaningful reforms are unlikely soon. The GGL is expected to publish a review in 2026 to evaluate whether the ISTG has achieved its goals. Until then, legal operators may remain frustrated by the rigorous regulations unless efforts to combat illegal competitors become more successful. The potential for growth in Germany’s online gambling market remains significant, but the development and maturation of its legal framework will be essential.
