Could Google help regulate German gambling’s black market battle?

Previously Google allowed companies active in the German gambling market to run ads targeting players in the country without checking whether these entities were licensed. 

From 25 September, however, those without a licence will have certification applications rejected, Google said in an update published last week. Companies without a GGL licence will have any existing certifications revoked on that date. 

While the policy appears to be directed at operators, Google specifies it includes “those offering gambling aggregation services, for example by linking to multiple offers of different operators on their landing page”. This suggests affiliates promoting unlicensed sites will also be affected. 

German gambling market dogged by black market competition

The update comes as German gambling operators contend with a rampant unlicensed market, not to mention claims and counter-claims about the size of that illegal market. 

In July the GGL claimed illegal gambling activity make up just 4% of the German gambling market in 2023, in its interim report on the state of the market. 

This falls far below independent estimates. A November 2023 report from the University of Leipzig said unlicensed gambling accounted for 48.8% of all activity in Germany, for example.

In the wake of the GGL’s annual report, the Deutscher Onlinecasinoverband (DOCV) pointed out that even using the regulator’s figures, a black market worth €400m to €600m accounted for at least 20% of all gambling activity. 

The regulator does have powers to tackle illegal activity, although measures such as IP blocking are caught up in legal proceedings. 

This plays out with the GGL due to deliver a report on the effectiveness of the fourth State Treaty on Gambling by 2026. However with the interim report delayed by months, the DOCV now expects that final assessment to be published in 2027 at the earliest. 

“We expect this [final report] not to come before 2027, which means for some of the measures, they will definitely have to find a way to implement those earlier on, because it will be three more years for the illegal market to thrive without having any consequences,” DOCV vice-president Simon Priglinger-Simader told iGB in July.