German gambling regulator claims progress in illegal market battle – industry unconvinced

Germany’s gambling market experienced accelerated growth during 2024, while changes to Google advertising rules helped to stem illegal operators, according to the national regulator. However, licensed German operators continue to dispute the figures.

In its annual report, the Gemeinsame Glücksspielbehörde der Länder (GGL) gambling regulator said GGR grew by 5% year-over-year to €14.4 billion. That figure is up 5% on 2023, outpacing the 2% year-over-year growth in the prior period.

Tax and levy revenues from gambling amounted to approximately €7 billion. In 2023, tax revenue from gambling was approximately €6.6 billion.

GGL targets illegal gambling market – but figures still don’t add up

In the illegal market during 2024, the GGL said it registered 858 German-language gambling websites operated illegally by 212 operators. This was slightly up on the 205 identified in 2023.

The GGL estimates that the illegal German language websites it recorded represent a market volume of between €500 million and €600 million. In 2023, the figure was estimated to be between €400 million and €600 million.

Illegal market volume is estimated to be approximately 3% to 4% of the entire legal market (terrestrial and online) and approximately 25% of the legal market for dangerous online gambling, such as virtual slot machines or sports betting.

Just how big is the illegal German gambling market?

That figure prompted major pushback from the industry, which argued it massively underestimated the scale of Germany’s offshore market. The latest figures have prompted even more debate on the matter.

At best, less than half of all gambling activity is channelled into the legal market, according to a University of Leipzig study.

But according to H2 Gambling Capital figures, the GGL still doesn’t capture the full scale of Germany’s illegal market and the Leipzig study may also be underestimating its size.

In 2024, H2 estimated just 40% of revenue was generated onshore. For 2025, it expects 36% of online gambling in Germany to be generated via legal sites.

Enforcement action ramps up in the German gambling market

In 2024, the GGL initiated 231 prohibition proceedings and over 1,700 websites were reviewed. In 2023, more than 1,800 websites were reviewed and prohibition proceedings were initiated in 133 cases.

Approximately 450 illegal gambling sites were no longer accessible from Germany in 2024 due to prohibition orders. Another 657 were no longer accessible due to geo-blocking based on the Digital Services Act (DSA).

The GGL also highlighted the positive impact of adjustments to Google’s advertising guidelines, which the regulator helped to shape. Since September 2024, only authorised providers in Germany have been allowed to advertise via Google Ads. This “significantly reduced the visibility of illegal offers”, the GGL said.

“Our measures are having an impact,” said Ronald Benter, chief executive of GGL. “Nevertheless, combating illegal offerings remains challenging and requires perseverance and close cooperation with national and international partners.”

Tipico executive queries GGL figures

At the time these new Google changes were introduced, industry figures wondered whether they would have a major impact.

And while the GGL hailed the impact of the Google changes on the illegal market, the industry remains unconvinced. In a LinkedIn post, Christian Heins, director of iGaming at Tipico, outlined his concerns about the accuracy of the GGL figures and its claims.

Heins believes that the online casino black market alone could easily be worth up to €2 billion. That figure is three times the total illegal market estimated by the GGL.

Heins based his figure on what he identifies as disparities between tax revenue and revenue. His estimate was also influenced by online traffic data, which suggests 50% more traffic for the black market than the legal market on average.

Heins also pointed to the impact of the Google changes, noting that December’s figures merely returned to July levels and remained stable through January. The Tipico executive said the figures only started dropping after this due to systematic reporting of black market operators and increased pressure on Google.

GGL to expand advertising monitoring

Last year, the GGL processed 230 permit and amendment applications and supervised 141 providers. In comparison, the GGL approved 39 applications for basic licenses to organise and broker cross-border gambling in 2023.

Looking ahead, the GGL said it expects further court rulings on its measures, thus providing even greater legal certainty in its approach. It plans to expand advertising monitoring, while the development of the use of safe servers is intended to improve oversight of the legal gambling market and enable more precise monitoring.

The GGL said a particular focus is on cooperation with national and international authorities to effectively curb the illegal gambling market. This will, it said, target not only the providers themselves, but also technical service providers, advertising partners and other supporting actors.

Benter added: “Our stated goal is to make the business model of illegal providers unattractive through a comprehensive package of measures. Combating illegal offerings remains a long-term process that requires strategic action, decisive action, and close interagency cooperation.”