GGL says illegal gambling still dominates online market

Germany’s central gambling authority, the Gemeinsame Glücksspielbehörde der Länder (GGL), has published its 2024 annual report, providing a comprehensive overview of key trends and regulatory activities across both the licensed and unlicensed segments of the national gambling market. While the regulated gambling sector has grown steadily in recent years, the report reveals a significant ongoing challenge: a substantial portion of Germany’s online gambling activity still occurs outside the legal framework.

According to the GGL, websites operated illegally in the German language generated between €500 million and €600 million in 2024. This equates to roughly 3–4% of the land-based gambling market, but more alarmingly, it constitutes approximately 25% of the total online gambling market, primarily in areas such as online slots and sports betting.

These figures have prompted renewed scrutiny over the effectiveness of enforcement measures and raised important questions regarding the structural obstacles regulators face when attempting to suppress illegal online gambling.

Regulated market sees moderate growth

Despite the persistence of illegal operators, the report offered some positive insights into the development of the legal gambling sector. In total, the legal market—encompassing both land-based and online operations—generated gross gaming revenue (GGR) of €14.4 billion, an increase of around 5% compared to the previous year. This figure reflects the enduring appeal of gambling services in Germany and the continued migration of users toward regulated platforms.

Approximately €7 billion of this revenue was collected in taxes and levies, reflecting the German government’s significant fiscal interest in the sector. Approximately €4 billion of the total revenue originated from operators licensed and overseen by the GGL, representing about 28 percent of the country’s regulated gambling sector. These statistics indicate steady progress in the central authority’s efforts to license and monitor providers under the current regulatory regime.

A growing concern over unlicensed operators

While revenue growth in the regulated market is a positive sign, the estimated €500–600 million generated by illegal sites remains a significant concern. The GGL emphasised that this figure should not be underestimated, especially given the potential for harm associated with unregulated gambling platforms. These sites often fail to implement adequate responsible gambling safeguards, such as deposit limits, self-exclusion tools, and age verification protocols.

The report’s findings reinforce long-standing concerns that many consumers, particularly those seeking higher betting limits or more aggressive bonus offers, continue to be drawn to illegal sites operating without German licences.

Enforcement actions and regulatory progress

Throughout 2024, the GGL intensified its enforcement efforts against illegal gambling operators. The regulator reported initiating 231 prohibition orders and conducting over 1,700 website reviews to detect and restrict access to illegal gambling content. As a result of these measures:

• Approximately 450 unlicensed gambling websites became entirely inaccessible from within Germany.
• A further 657 websites were made inaccessible via geo-blocking tools, preventing users with German IP addresses from accessing the content.
• Additionally, the GGL processed 230 permit and amendment applications and supervised 141 active providers, reflecting a continued focus on regulatory oversight and license compliance.

Cooperation with tech platforms strengthens enforcement

One of the key tools in the GGL’s enforcement arsenal is its collaboration with technology platforms, particularly Google Ads. The regulator confirmed that it worked closely with Google to ensure only licensed gambling operators could access its advertising system within Germany.

By restricting access to Google Ads, the GGL has been able to “significantly reduce the visibility of illegal offers”, a development considered instrumental in directing users toward the legal market. The regulator's cooperation with advertising networks is part of a broader strategy to eliminate the financial and promotional lifelines of illegal operators.

Commentary from GGL leadership

In remarks accompanying the publication of the report, Ronald Benter, CEO of the GGL, acknowledged both the progress made and the ongoing difficulties the authority faces.

“Our measures are having an impact. Nevertheless, combating illegal offerings remains challenging and requires perseverance and close cooperation with national and international partners,” he stated.

Benter’s comments reflect the increasingly international character of illegal gambling, with many unlicensed operators based outside the European Union and employing sophisticated technology to evade regulatory detection and enforcement.

Germany’s regulatory framework and its evolution

The GGL was established in 2021 under the Fourth State Treaty on Gambling (GlüNeuRStV), which came into effect in July of that year. The Treaty sought to unify gambling regulation across Germany’s 16 federal states, introducing a national licensing system for online slots, poker, and sports betting.

Under the Treaty, operators must meet rigorous compliance standards concerning player protection, data transparency, advertising restrictions, and financial reporting. However, critics argue that the regime’s restrictions—such as low maximum monthly deposit limits and a ban on live betting for sports—have driven some players to continue using black market websites.

Persistent challenges in curbing illegal activity

The GGL’s latest report underscores a central dilemma in modern gambling regulation: how to eliminate illegal offerings without pushing players into unsafe or unregulated environments. Although the authority has been able to shut down hundreds of websites or restrict their visibility, the decentralised and transnational nature of the internet continues to pose substantial obstacles.

Illegal operators often host their websites outside the European Union and use third-party domains or mirror sites to remain accessible. They also leverage cryptocurrencies, anonymising tools, and aggressive marketing tactics to reach German customers. This cat-and-mouse dynamic between regulators and black market operators has made complete eradication extremely difficult.

Legal and policy implications

From a legal standpoint, the continued existence of a sizeable unregulated market raises important questions about policy effectiveness, consumer protection, and cross-border regulatory cooperation. Germany, like other EU states, faces limitations when it comes to enforcing national laws against offshore operators without mutual legal assistance agreements.

Moreover, should a significant portion of consumer traffic remain directed toward illegal sites, it may suggest that certain aspects of the legal offering—such as the €1 stake limit for slots or mandatory breaks—require further evaluation. Balancing robust consumer protection with user preferences remains one of the most complex challenges for any modern gambling regulator.

Future outlook and strategic direction

Moving forward, the GGL is expected to further intensify its cooperation with both domestic institutions and international partners. One area of focus is likely to be increased collaboration with payment service providers, which can be instrumental in cutting off financial transactions to and from unlicensed gambling sites.

The regulator is also expected to refine its digital tools for monitoring and enforcement, including the use of automated scraping technologies and AI-driven analytics to identify unlawful operators more quickly.

Continued dialogue with consumer advocacy groups, licensed operators, and EU regulatory counterparts will be essential to ensure the sustainability of Germany’s legal gambling framework while minimising harm and avoiding the resurgence of a shadow market.

Conclusion

While Germany’s regulated gambling sector continues to demonstrate solid growth, the enduring presence of illegal operators—especially in the online domain—presents serious regulatory and consumer protection challenges. The GGL’s efforts, including enforcement actions, platform restrictions, and cooperation with international stakeholders, are bearing some fruit. However, the fight against unlawful gambling activity continues, requiring constant oversight, flexible regulatory strategies, and long-term legal and technological commitment.

FAQs

What is the GGL in Germany?
The GGL, or Gemeinsame Glücksspielbehörde der Länder, is Germany’s national gambling authority responsible for regulating and supervising both online and land-based gambling.

How much is the illegal gambling market worth in Germany?
In 2024, the GGL estimated that illegal German-language gambling websites generated between €500 million and €600 million.

What percentage of the online gambling market in Germany is illegal?
According to the GGL, approximately 25% of online gambling in Germany is carried out through illegal operators.

What measures has the GGL taken against illegal operators?
The GGL has issued over 230 prohibition orders, reviewed more than 1,700 websites, and collaborated with platforms like Google Ads to reduce illegal visibility.

How many illegal gambling websites were blocked?
About 450 websites became inaccessible from Germany, while another 657 were restricted through geo-blocking.

Why do people still use illegal gambling websites in Germany?
Some consumers are drawn to illegal sites due to higher limits, less regulation, and more aggressive promotional offers not allowed under German law.

How much revenue did the legal gambling sector generate in 2024?
Germany’s legal gambling sector generated €14.4 billion in gross gaming revenue in 2024.

What share of the legal market is regulated by the GGL?
Operators licensed by the GGL generated approximately €4 billion, accounting for about 28% of the legal gambling market.

Does the GGL work with international partners?
Yes, the GGL cooperates with international regulators, technology firms, and payment providers to combat illegal gambling.

What are the challenges in stopping illegal gambling in Germany?
Key challenges include offshore hosting, use of cryptocurrencies, advertising evasion, and limited jurisdiction over operators outside the EU.