GGL vs. Black Market: Real Action or Just Noise?

Germany’s gambling regulator, the Gemeinsame Glücksspielbehörde der Länder (GGL), is at it again. At the Berlin Congress organized by the Deutsche Automatenwirtschaft (DAW), GGL Chairman Ronald Benter made his usual call for stricter measures against the so-called “black market.”

His latest push? A framework for blocking illegal gambling advertisements through IP restrictions.

Sounds serious, right? But if you’ve been paying attention, you’ll know this isn’t exactly new. Benter’s been talking about this for years, yet, we’re still here.

A framework that’s been “coming soon” for years

Back in late 2023, there was talk about deleting Section 284 of the German Criminal Code, a move that stripped the GGL of its ability to file criminal charges against illegal operators. Benter and his team weren’t happy, so in early 2024, they sent a letter to the Federal Government practically begging them to expand the section instead. The idea was to include operators based abroad, but as of today, that proposal is still sitting in some bureaucrat’s inbox.

Benter keeps saying that Germany needs a regulatory balance between market attractiveness and player protection. In theory, that makes sense. In practice, the GGL seems far more interested in going after advertising violations than dealing with actual illegal operators.

Fighting ads while ignoring bigger problems

If there’s one thing the GGL is really good at, it’s chasing down advertisers. The regulator even took a social lottery provider to court because its logo appeared in educational materials about charitable work.

Yes, you read that right. The GGL’s argument? Just seeing the logo could “indirectly” promote gambling. The case dragged on through multiple courts, until the Federal Administrative Court of Mainz (BVerwG) ruled in the GGL’s favor.

The result? A precedent that says even non-promotional branding can be classified as gambling advertising. It’s the kind of overreach that makes you wonder whether the regulator’s real goal is protecting consumers or just flexing its authority.

The study that will tell us what we already know

The GGL has also commissioned a two-year study on gambling advertising, conducted by eye square GmbH. The goal is to analyze how advertising impacts both gamblers and vulnerable groups. It’s part of the larger evaluation of GlüStV 2021, and we’re told it’ll help determine whether the current ad restrictions are working.

Let’s be honest. The study’s conclusion is all but decided before the first page is written. Given the GGL’s track record, there’s little doubt it will recommend even stricter advertising rules while doing nothing about the root of the problem: the fact that German players still flock to offshore casinos because the legal market is a nightmare to navigate.

Missing the real fight

For all its talk about fighting the black market, the GGL doesn’t seem too interested in actually shutting down illegal sites. Instead, it’s focused on:

• Advertising cases that most people wouldn’t even consider violations.
• Studies that will likely justify more regulations rather than solve existing problems.
• Public statements about cracking down on the black market without real enforcement.

What’s missing? A practical approach. The GGL should be working with banks and payment providers to block unauthorized transactions, ensuring that licensed operators can actually compete with offshore sites, and improving the licensing process to encourage compliance rather than pushing operators away.

Until that happens, all these announcements and studies won’t change a thing. The black market will keep thriving, and German players will keep going where they’ve always gone; to casinos that actually let them play.

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FAQs

What is the GGL, and what is its role in Germany?
The Gemeinsame Glücksspielbehörde der Länder (GGL) is Germany’s gambling regulator, overseeing the enforcement of gambling laws and regulations.

Why is the GGL pushing for stricter gambling ad regulations?
The GGL argues that stricter ad regulations help protect consumers and prevent illegal gambling, though critics say it focuses too much on advertising.

What is the proposed IP-blocking framework for illegal gambling ads?
The GGL wants to introduce IP restrictions to block advertisements from unlicensed gambling operators targeting German players.

Why was Section 284 of the German Criminal Code removed?
Its removal limited the GGL’s ability to file criminal charges against illegal gambling operators, a decision the regulator opposed.

What was the GGL’s case against a social lottery provider about?
The GGL argued that a lottery logo in educational materials constituted indirect gambling advertising, leading to a controversial court ruling.

What is the goal of the GGL’s two-year gambling ad study?
The study, conducted by eye square GmbH, aims to assess how gambling ads affect players, but many expect it to justify stricter regulations.

Why do German players still use offshore casinos?
Many players find Germany’s legal gambling market too restrictive, pushing them to unlicensed offshore casinos that offer more flexibility.

What enforcement measures does the GGL prioritize?
The GGL mainly targets advertising violations rather than actively shutting down illegal gambling sites or blocking unauthorized payments.

How could Germany better tackle the black market?
Experts suggest working with banks to block transactions, streamlining licensing, and making the legal market more competitive.

What is the main criticism of the GGL’s approach?
Critics argue that the GGL focuses too much on advertising rules while ignoring the real issue: illegal operators attracting German players.