DOCV disputes GGL data on size of Germany’s online black market

The debate surrounding the size and influence of Germany’s online gambling black market has intensified following fresh criticism from the Deutscher Online Casinoverband. The association, commonly known as DOCV, has openly questioned recent estimates published by the Gemeinsame Glücksspielbehörde der Länder, referred to as GGL, arguing that the regulator’s figures significantly understate the true scale of unlicensed gambling activity.

At the centre of the discussion is the concept of channelisation, which measures the proportion of players using licensed operators rather than unregulated platforms. According to the GGL, its latest analysis indicates that approximately 77.03 per cent of online gambling activity in Germany is channelled through regulated providers. While this suggests a majority of users are engaging within the legal framework, critics argue that the remaining share attributed to the black market may be considerably larger than official estimates indicate.

GGL report presents stable but contested findings

The GGL’s conclusions are based on a study conducted in collaboration with the Blockchain Research Lab. The report estimated that gross gaming revenue generated by unlicensed operators reached approximately €547 million in 2024, marking an increase from €466 million in 2023. This represents a notable rise of roughly 17 per cent year-on-year.

Despite this growth, the regulator has stated that the findings broadly align with its expectations and reflect a relatively stable market structure under Germany’s current regulatory framework. The GGL has consistently maintained that its policies are gradually improving market channelisation while ensuring consumer protection and regulatory oversight.

However, these conclusions have not gone unchallenged.

DOCV raises concerns about methodology and assumptions

Simon Priglinger-Simader, vice president of DOCV, has been particularly vocal in disputing the regulator’s findings. He has described the reported channelisation rate as “conservative” and potentially misleading, suggesting that methodological limitations may have resulted in an incomplete picture of the market.

According to Priglinger-Simader, the study suffers from what he characterises as “non-representative sampling,” arguing that the data collection process may not adequately capture the behaviour of users who engage with unlicensed gambling platforms. He further stated that the findings are “not consistent with the observed tax numbers we know,” implying a discrepancy between reported figures and actual fiscal indicators.

These concerns reflect a broader industry debate about how best to measure illegal or unregulated economic activity, particularly in sectors where user disclosure may be unreliable.

Challenges in measuring illegal gambling participation

One of the key issues highlighted by DOCV relates to what is commonly referred to as recall bias. This phenomenon occurs when survey respondents provide inaccurate or incomplete information, often due to memory limitations or reluctance to disclose certain behaviours.

Priglinger-Simader underscored this challenge by noting: “When you are asking someone about whether they are participating in illegal gambling, most likely they will say ‘no’.” This observation points to a structural limitation in survey-based methodologies, especially when addressing activities that may carry legal or social stigma.

In addition to survey limitations, DOCV argues that behavioural incentives play a significant role in driving users toward unlicensed platforms. These platforms often operate without the regulatory constraints imposed on licensed operators, including limits on losses, betting speeds and promotional offers.

Competitive imbalance between licensed and unlicensed operators

DOCV has suggested that stricter regulatory requirements in Germany may inadvertently contribute to the attractiveness of offshore or unlicensed gambling services. Licensed operators must adhere to a range of consumer protection measures, including deposit limits and restrictions on gameplay intensity. While these rules are designed to safeguard players, they may also reduce the competitiveness of legal offerings in comparison to less regulated alternatives.

Priglinger-Simader indicated that licensed operators have received feedback from customers who reported switching to unlicensed platforms specifically to avoid these restrictions. Such anecdotal evidence, while not definitive, highlights a potential tension between regulatory objectives and market dynamics.

The association has therefore called for a more nuanced assessment of the market that considers both regulatory effectiveness and user behaviour.

Alternative research suggests higher black market participation

DOCV has pointed to its own research as an alternative benchmark. A study conducted in 2023 by Gunther Schnabl of the University of Leipzig suggested that approximately half of German online gamblers may have used illegal platforms at some point. This estimate significantly exceeds the figures presented by the GGL.

While methodologies differ between studies, the divergence in findings underscores the complexity of accurately quantifying unlicensed gambling activity. DOCV maintains that its research offers a more realistic perspective on player behaviour, although it also acknowledges the inherent challenges in measuring such activity.

An updated version of this study is expected in mid-2025, incorporating new data sources including market analytics and revised classifications of illegal operators. The forthcoming report may further inform the ongoing policy debate.

Broader concerns raised by national surveys

The discussion around black market gambling is occurring alongside wider scrutiny of Germany’s regulatory environment. The Glücksspiel-Survey 2025, conducted by researchers from the Institute for Interdisciplinary Addiction and Drug Research and the University of Bremen, has highlighted concerns regarding gambling advertising and player protection.

The survey recommends a shift toward what it describes as “structural prevention rather than relying primarily on individual responsibility to minimise gambling risks.” This approach emphasises systemic measures, such as stricter controls on advertising and enhanced monitoring of operator practices, rather than focusing solely on player behaviour.

These findings suggest that the effectiveness of Germany’s gambling framework is being evaluated from multiple perspectives, including public health, consumer protection and market regulation.

Regulatory review of the Interstate Gambling Treaty

All of these developments come at a critical juncture, as the GGL prepares to review the first five years of Germany’s Interstate Gambling Treaty. This legislative framework, which governs online gambling across the country, was introduced to create a unified regulatory system that balances market access with player protection.

The review is expected to be presented to the Bundestag later this year. It will assess whether the treaty has achieved its key objectives, including improving channelisation, reducing illegal gambling activity, enforcing advertising standards and ensuring the sustainability of licensed operators.

Given the contrasting views presented by the regulator and industry stakeholders, the review is likely to play a significant role in shaping future policy decisions.

Conclusion

The ongoing debate between DOCV and the GGL highlights the inherent complexity of regulating and measuring online gambling markets in a rapidly evolving digital environment. While the regulator maintains that its data reflects a stable and improving landscape, industry representatives argue that methodological limitations may obscure the true extent of black market activity.

At its core, the discussion raises broader questions about how best to balance consumer protection with market competitiveness. Stricter regulations may enhance player safety, but they may also drive some users toward less regulated alternatives if not carefully calibrated.

As Germany approaches a formal review of its gambling framework, the contrasting perspectives offered by regulators, industry bodies and academic researchers will likely inform a more comprehensive understanding of the market. The outcome of this process could influence not only national policy but also broader regulatory approaches across Europe.

Ultimately, achieving an effective balance between enforcement, consumer protection and market viability remains a complex task that requires ongoing analysis, transparent data and constructive dialogue among all stakeholders.

FAQs

What is channelisation in online gambling?
Channelisation refers to the percentage of players who use licensed and regulated gambling platforms instead of unlicensed operators.

Why is DOCV challenging the GGL data?
DOCV believes the methodology used by the GGL underestimates black market activity and does not reflect real market conditions.

What did the GGL report state about the black market?
The GGL estimated that unlicensed gambling generated €547 million in revenue in 2024 with a channelisation rate of 77.03 per cent.

What is recall bias in gambling studies?
Recall bias occurs when survey participants provide inaccurate answers often due to memory issues or reluctance to admit certain behaviours.

Who is Simon Priglinger-Simader?
He is the vice president of DOCV and a key voice in the debate on Germany’s gambling regulation.

What alternative research has DOCV cited?
DOCV referenced a study by economist Gunther Schnabl suggesting that around half of German players may use illegal gambling platforms.

What is the Glücksspiel-Survey 2025?
It is a national survey examining gambling behaviour and risks in Germany conducted by research institutions.

What changes are being suggested for regulation?
Researchers have recommended stronger structural prevention measures rather than relying mainly on individual responsibility.

What is the Interstate Gambling Treaty?
It is Germany’s legal framework governing online gambling across all federal states.

What will the Bundestag review involve?
The Bundestag will assess whether the current gambling laws have achieved goals such as player protection and reducing illegal activity.