Illegal Gambling Domain Remains Online Despite Years of GGL Action

An illegal gambling domain is still online. Why has nobody taken it down?

There are moments when regulation becomes so complicated that everybody starts discussing procedures and forgets to look at the obvious thing sitting in front of them. Lottoland.com is one of those moments. Germany's national gambling regulator says the international site has no German permission, is not on the official whitelist and is illegal for German consumers. Lottoland, meanwhile, is still online, still publishing German-language lottery pages and still telling readers on its current El Gordo page that German players can participate legally from Germany. Those two positions cannot both describe the same regulatory reality.

The GGL's current El Gordo consumer guidance is not vague. It says the operator behind lottoland.com has no permission to offer or broker online gambling in Germany, is absent from the whitelist and is therefore illegal. The international site is equally unambiguous in the other direction. Its current 2026 El Gordo page asks whether El Gordo can be played legally from Germany and answers yes. That is not some obscure affiliate page somebody forgot to delete. It is the operator's own German-language commercial material, live years after the regulator says it began using every available instrument against the group.

At that point I am far less interested in another GGL statistic telling me how many websites were examined, how many hearings were opened or how many payment providers received letters. I want to know why a major domain that the authority publicly identified years ago can still sit there and tell German consumers the opposite of what the regulator says. If the GGL wants to be judged as an enforcement authority rather than an administrative correspondence department, that is the test.

This is not a legal grey area created last week

The first defence available to any regulator is complexity. Sometimes that defence is justified. Gambling law is full of cross-border structures, different product classifications, foreign licences and competing court decisions. Lottoland.com does not give the GGL that comfort. The authority itself has already done the classification for us.

The GGL says the international Lottoland offer is unlicensed and illegal in Germany. It separately recognises Lottoland Deutschland GmbH as a licensed commercial lottery intermediary using authorised German domains. Those are different propositions. A German licence held by one company for one permitted activity does not magically legalise every international offer carrying the same brand name. The regulator itself continues to draw that distinction, which is why the continuing accessibility and visibility of lottoland.com matters.

This also means the 28 August article should not drift back into the previous question of what the GGL knew before licensing Lottoland Deutschland. That was a licensing and corporate-relationship investigation. This one is simpler and, frankly, more embarrassing. The regulator says this particular domain is illegal. The domain is still there. The job is to follow the enforcement chain until somebody explains why.

The GGL chose Lottoland as an early demonstration of its new power

The timeline destroys any attempt to present this as a fresh problem. On 7 October 2022, the GGL published a statement headed GGL intensifies fight against illegal gambling offers from Lottoland. The authority said it was using all instruments available to it consistently, including payment blocking and network blocking, and it described early payment-provider withdrawals as successes.

That was nearly four years ago. In November 2023 the authority issued a specific warning around El Gordo. Its current consumer guidance still identifies lottoland.com as illegal. If the GGL had picked some anonymous Curaçao clone that changed domains every fortnight, the survival of one address would tell us very little. Lottoland is a major, well-resourced and highly visible brand that the regulator itself chose as an example of why concentrated national enforcement was needed. That makes it the right benchmark, not an unfair one.

When the GGL was created, the political sales pitch was that fragmented state enforcement was no longer adequate for cross-border online gambling. One national authority would have the expertise, the data and the full enforcement toolkit. Fine. Then this is exactly the type of case by which that promise should be measured. Not by the easy operators that disappear after the first hearing, but by the sophisticated target that knows how to stay in business.

The most awkward evidence is the website itself

The strongest evidence in this article is not a leaked memo, an angry operator submission or an industry rumour. It is the current public internet. Lottoland's own German-language page promotes the 2026 Spanish Christmas lottery, discusses German winners and states that German players can participate legally. Search engines index the material. German-language users can find it in an ordinary search journey.

The GGL says the opposite. Its official guidance says participation through the international offer is illegal because the site lacks German permission and secondary lotteries are not permit-eligible under the GlüStV 2021. This is about as clean a regulatory contradiction as one can ask for. The authority says no. The commercial website says yes. The website remains visible enough that the authority still needs consumer guidance explaining why the website is wrong.

If a regulator has spent years enforcing against a named operator, the end result should eventually become more persuasive than a FAQ. Consumer education is useful at the start of an enforcement problem. Years later, when the same domain remains searchable and commercially expressive, continuing to warn consumers starts to look less like enforcement success and more like an admission that the underlying offer was never properly separated from the German market.

Germany tried IP blocking and discovered that its law did not say what politicians thought it said

The GGL did try one of the obvious routes. It pursued blocking orders against internet access providers. Then the courts explained the unpleasant part. In March 2025 the Federal Administrative Court held that the relevant GlüStV provision does not allow ordinary access providers to be treated as convenient blocking targets merely because they carry traffic. Under the statutory cross-reference to the old Telemediengesetz, the requirements are far narrower. An access provider generally has to do considerably more than transmit somebody else's data before this specific power can bite.

That judgment matters because it exposed a hole in the enforcement machinery. The GGL had a politically impressive power on paper and a much less useful one in court. Malta Media covered the problem when we examined how the GGL continued domain-blocking efforts after the ruling. The judges did not legalise the gambling offer. They told Germany that the law it had written did not give the regulator the broad ISP-blocking route it wanted.

I am not going to blame the GGL for obeying a judgment. The authority cannot invent powers because the legislature drafted a weak provision. But once the court closes one road, a serious enforcement authority has to show what happens next. If the answer is that the legislature needs to repair the law, then say that loudly and repeatedly. Do not continue selling headline enforcement numbers while one of the best-known illegal targets remains a live commercial presence.

Blocking an ISP was never the whole enforcement chain

The court defeat does not explain everything. It explains why one form of access blocking became legally difficult. It does not explain the host, the registrar, payment infrastructure, advertising visibility, search discovery or the commercial services that allow a gambling operation to keep addressing a market.

Hosting is particularly important. The Federal Administrative Court itself distinguished ordinary access providers from service providers that may have a more direct relationship with the unlawful content. That does not mean the GGL can order a foreign host to delete an international website globally. It means the legal analysis changes once a provider is more than a neutral pipe. After years of public illegality findings, the fair question is therefore basic: which hosts and infrastructure providers were identified, which were notified and what happened?

The same is true of domain registration. I do not accept the simplistic internet argument that DENIC, a .com registrar or another registry actor can simply be ordered to delete a global domain because Germany dislikes one market-facing use of it. That would be legally naïve. But a regulator that has known the operator and domain for years should be able to tell the public whether registrar-level action was explored, what legal threshold prevented it and whether legislative change is required. It is complicated, not an enforcement strategy.

Payment blocking sounds impressive until the customer still has a way to pay

The GGL has always sounded more confident about payment blocking. Its 2022 Lottoland statement celebrated payment providers ending cooperation. Malta Media later examined the mechanism in Payment systems in gambling regulation explained because, in theory, attacking the money flow is often smarter than fighting the domain. A gambling website without reliable deposits and withdrawals is commercially wounded even if the homepage remains online.

The difficulty is durability. Payment blocking is effective when it removes the practical ability to transact, not when one processor leaves and another appears. The GGL itself says it conducts test transactions and follows the companies’ payments behind familiar logos. Good. Then a prominent long-term target such as Lottoland should produce measurable results. How many German payment routes were removed? How long did replacement routes take to appear? What proportion of attempted German transactions is now blocked? Those are enforcement metrics. We contacted a payment company‘ is an activity metric.

This distinction matters because the regulator's public communication constantly mixes the two. A letter, a hearing and a payment-provider withdrawal are all presented as enforcement progress. They may be. But progress is not the same thing as outcome. If the customer can still find the site, read German marketing, create a commercial relationship and route money through whatever method remains available, the regulator has not, Search visibility makes the enforcement failure visible to everyone

The GGL cannot order Google to rewrite the internet simply because an offer is illegal under German gambling law. Search engines have their own legal responsibilities and ranking systems. But visibility is still part of the regulatory outcome because it determines which operators’ consumers encounter in the first place.

Malta Media has already asked whether Germany has genuinely reduced illegal gambling visibility and why unlicensed gambling sites remain visible despite years of enforcement. Lottoland is the cleanest practical example. A consumer does not need the dark web, a Telegram group or an obscure affiliate forum. Search engines continue to surface German-language pages for a brand the regulator publicly calls illegal.

That is not merely a marketing irritation. Germany's entire channelisation strategy assumes consumers should be pushed towards licensed offers and away from illegal ones. A major illegal offer that remains highly discoverable keeps competing for exactly the consumer attention the licensing regime is supposed to redirect. Every year that continues weakens the argument that the legal market is being protected by effective enforcement rather than simply being burdened by rules illegal operators can avoid.

The regulated market gets the full force of Germany. Offshore operators get a long chase

This is where the Lottoland domain becomes politically uncomfortable. Germany can be brutally effective against companies already inside the licensing system. A licensed operator has a known entity, directors, lawyers, compliance systems, German market access and a licence that can be suspended or revoked. The GGL holds the pressure point in its hand.

An offshore operator is harder. It can resist orders, fight blocking, change technical providers and rely on cross-border infrastructure. That is true. It is also precisely why the GGL was created. If the authority's practical power is overwhelming against the businesses that submitted to German regulation and frustratingly limited against the businesses that did not, the regulatory incentive is upside down.

This is not a theoretical concern. Malta Media has already examined Germany's gambling enforcement under scrutiny and the way compliance, reliability and technical obligations can become existential for licensed operators. The legal market is asked to prove itself continuously. Lottoland.com demonstrates how much more patient the system becomes when the target sits outside that permission structure.

The GGL numbers are not meaningless. They are just not enough

The regulator can point to substantial enforcement statistics. The base investigation records hundreds of websites becoming inaccessible, network-blocking results, payment-blocking outcomes, hearings, investigations and criminal referrals. Those achievements should not be dismissed simply because one difficult operator survives. A serious article should acknowledge that.

But aggregate totals are where regulators can hide difficult failures in plain sight. If 100 small domains disappear after one warning while a nationally visible brand survives years of measures, the 100 successes may dominate the annual report while the unresolved operator continues to capture far more consumer attention. Market impact is not a simple domain count.

The GGL itself says it prioritises illegal operators partly according to market presence. That is sensible. The logical consequence is that unresolved high-presence targets should carry greater weight when we judge the effectiveness of enforcement. A regulator cannot use market significance to justify priority and then use raw website totals to avoid discussing why a priority target remains visible.

The legislature has failed as well, but that does not let the regulator off the hook

The Federal Administrative Court ruling proved that part of this problem belongs to lawmakers. Germany wrote an IP-blocking provision that looked tougher in a press release than it was in court. If broader access-provider powers are genuinely necessary and can be made compatible with proportionality and EU law, the Länder need to write them properly.

The same applies to hosting, registrars and other intermediaries. If the legal basis is too weak to compel action in a targeted German market case, the gap should be identified clearly. A regulator with front-line experience is in the best position to tell lawmakers where the legislation fails. What I do not want to hear after four years is another generic statement that all available instruments are being used. If all available instruments leave the same obvious target commercially visible, then either the instruments are inadequate or their use is inadequate. Pick one and explain it.

Lottoland is difficult. That is why it is the right test

It would be childish to argue that the GGL should be able to delete lottoland.com from the entire global internet. The website serves markets outside Germany and operates through an international business. German law does not govern the world. Nor should a German regulator be allowed to erase lawful foreign activity merely because part of the same domain conflicts with German rules.

But that defence misses the point. The test is not whether the global website still exists. The test is whether German consumers remain a commercially meaningful audience for the illegal offer. If geo-restriction, payments, discovery and German-language solicitation still leave the operator relevant enough that the GGL has to keep warning consumers, then the German-facing enforcement problem is not solved.

The difficult operators are the ones that tell us whether a regulator is effective. Any authority looks competent when the target cooperates immediately. The real test is the operator with money, lawyers, international infrastructure and the appetite to fight. Germany knew that when it concentrated enforcement powers. Lottoland is not an unfair benchmark. It is the benchmark the system was supposedly built for.

Four years later, the regulator is still explaining the same illegal offer

Strip the story down to its timeline. In October 2022 the GGL publicly said it was intensifying the fight against Lottoland and using all available instruments. In November 2023 it issued specific El Gordo consumer warnings. In March 2025 Germany's highest administrative court exposed a major weakness in the ISP-blocking route. In August 2026 the GGL's current guidance still says lottoland.com is illegal. At the same time, Lottoland's own German-language 2026 El Gordo material says German players can participate legally.

That is not a resolved enforcement story. It is a live contradiction between regulator and operator, visible to the same consumer both sides claim to be informing. The GGL may have disrupted payments. It may have forced changes invisible from the outside. It may have spent thousands of staff hours and won smaller battles along the way. None of that answers the simple question a consumer can ask from a browser today: why is the illegal offer still here telling me it is legal?

Somebody has to own the final result. The ISP can point to the Federal Administrative Court. The host can point to jurisdiction. The registrar can point to the global domain system. The payment company can withdraw and leave another processor to appear. Search engines can say they are not gambling regulators. Every individual explanation may be technically valid. The consumer still sees the website.

The GGL was created to stop Germany's illegal gambling response from dissolving into exactly that chain of excuses. If the authority lacks the legal power, it should force the legislative failure into public view. If intermediaries cannot practically be compelled to act, it should publish the gap. If its measures have materially reduced Lottoland's German business, it should show the outcome. What it cannot do forever is count administrative activity while one of its most obvious long-term targets keeps contradicting it on a live German-language webpage.

After four years, asking why nobody has taken the German-facing illegal offer down is not impatience and it is not an unrealistic demand that Germany police the global internet. It is the most basic performance question an enforcement authority can be asked: once you identify a major operator as illegal, how long should the public wait before the result becomes more convincing than the warning?

FAQs

Why does the GGL consider Lottoland.com illegal in Germany?
The GGL states that the international Lottoland.com website does not have permission to offer or broker online gambling in Germany and is not included on the official German gambling whitelist.

Is Lottoland Deutschland GmbH licensed in Germany?
Yes. The GGL distinguishes between the international Lottoland.com offer and Lottoland Deutschland GmbH, which is licensed as a commercial lottery intermediary for authorised German domains. The GGL's current whitelist confirms Lottoland Deutschland GmbH and lists lottoland-deutschland.de among its permitted websites.

How long has the GGL been taking action against Lottoland?
The GGL publicly announced on 7 October 2022 that it was intensifying enforcement against illegal Lottoland gambling offers and using measures including payment blocking and network blocking.

Why is Lottoland.com still significant to Germany's illegal gambling debate?
Lottoland.com remains a prominent and discoverable international domain with German-language content. The article argues that its continued visibility makes it an important test of whether German enforcement can produce measurable outcomes against large cross-border operators.

What happened to Germany's IP-blocking approach?
In March 2025, the Federal Administrative Court ruled that the relevant provisions of the GlüStV did not provide the broad authority needed to impose blocking obligations on ordinary internet access providers simply because they transmit traffic.

What other enforcement measures can be used against illegal gambling?
The article discusses payment blocking, action involving hosting and infrastructure providers, domain registration, advertising visibility and search discovery as other parts of the enforcement chain. The GGL also identifies prohibition proceedings, payment blocking, IP blocking and cooperation with other authorities among its enforcement instruments.

Why is payment blocking important in gambling enforcement?
Payment blocking aims to disrupt deposits and withdrawals rather than merely restricting access to a website. The article argues that its effectiveness should be measured by whether German consumers can still transact, not simply by how many payment providers receive enforcement notices.

How does search visibility affect illegal gambling enforcement?
Search visibility matters because consumers can continue discovering unlicensed gambling offers through ordinary search journeys. The article argues that highly visible illegal operators can continue competing for the same consumer attention that Germany's regulated market is intended to capture.

Does the GGL report successes against illegal gambling?
Yes. The article acknowledges that the GGL reports substantial enforcement activity, including websites becoming inaccessible, payment-blocking outcomes, investigations, hearings and criminal referrals. It argues, however, that aggregate totals do not necessarily show how effectively major high-visibility operators are being contained.

What is the central enforcement question raised by the Lottoland case?
The central question is whether German consumers remain a commercially meaningful audience for an offer that the regulator considers illegal. The article argues that the effectiveness of enforcement should ultimately be judged by outcomes such as reduced accessibility, payments, discovery and German-facing solicitation.