Germany black market accounts for up to 4% of GGR in 2023, GGL claims

The black market recorded between €400m and €600m in revenue during the period, while the legal market brought in €13.7bn in GGR for the year, reflecting 2% in annual growth.  

Throughout the period up to 1,864 websites were checked and, in 133 instances, the regulator proceeded to block the operation, the report said. Of these, 87 related to those offering illegal gambling services while 46 were connected to the advertising of black-market operators. 

Overall, GGL processed a total of 438 cases of suspected illegal gambling or advertising during the 12-month period for illegal gambling 

Of those flagged, 63 black market operators stopped their services, or advertising of services, as a result of hearings or prohibition orders made by GGL during the 12 months.  

“Those providers who do not discontinue their services despite prohibition orders are often based in countries outside the EU,” the regulator noted.  

The GGL imposed two fines of €50,000 each to enforce the prohibition orders regarding illegal gambling and advertising during 2023.  

In the report, the regulator said it had been embroiled in up to 117 lawsuits initiated by various online gambling providers across different verticals.  

In GGL’s 2021-22 report, 157 instances of illegal gambling and advertising illegal gambling were flagged, with 68 prohibition proceedings initiated.  

Within the legal market, online gambling accounted for 8% or €400m in GGR in 2023, while sports betting contributed a turnover of €1.8bn, with a 13% share of the overall market. 

Commenting on the licensing process, GGL said in its report that it had faced delays in testing games before they went out into the market.  

The regulator said this was down to suppliers not providing information in time or at all.  

“Resources were temporarily hired to provide temporary support with game testing. This led to a substantial improvement within the first two quarters of 2024,” the regulator said.  

Germany’s gaming regulation – the 2021 Interstate Treaty on Gambling – created a comprehensive online betting and gaming market in the country for the first time. Then, at the start of 2023, the central regulatory authority, the Joint Gambling Authority (GGL), opened its doors. 

Huge if true

Many industry stakeholders have criticised Germany’s regulatory process, noting that the market is not friendly to commercial operators.

Numbers from other sources also suggest the regulator’s figures potentially ignore a far larger black market issue.

A November 2023 study by Gunther Schnabl of the University of Leipzig, for example, suggested around 48.8% of players still gambled via offshore sites.

Commissioned by the German Sports Betting and Online Casino Associations, the study also estimated up to three quarters of online revenue was generated offshore.

The current regulatory framework has been described by the German Sports Betting Association (DSWV) as “the most restrictive in the world”.