German gambling regulator defends data on unlicensed gambling 

The GGL has responded to concerns about the size of the unlicensed gambling market in Germany.

Germany.- The new German federal gambling regulator, the GGL, has sought to clarify its position on data collection to measure the size of the unlicensed market. Its response comes after the trade bodies DSWV and DOCV warned that half of gambling in Germany takes place on the black market.

The GGL recognised that studies to measure the size of the illegal online gambling market were “contentious” and that some had found different results from the data obtained by the state. It said that “scientific discourse on survey methods” was welcomed and said it was “open to new or further developed approaches to obtaining knowledge” and was continually developing its own methods of data collection.

However, the GGL said it was sticking with its previous estimate that the market volume of unlicensed gambling was around €300m-€500m, or 2 to 4 per cent of the size of the regulated market. It estimates that 800 to 900 unlicensed websites offer online gambling, including casino, virtual slots, online poker, sports betting and secondary lotteries. It also insisted that its method of measuring the market was the most comprehensive.

“The GGL firmly rejects criticism from the industry that the GGL’s approach to collecting data from the illegal online gambling market is based on a static model that does not take market changes into account.”

It added: “Collecting data on illegal online gambling is complex due to the ever-changing nature of the black market. All collected data is estimated, providing a snapshot of the market at a specific time.”

The online casino association DOCV and the sports betting association DSWV had commissioned the economist Gunther Schnabl of the University of Leipzig to conduct independent research in the black market. According to the findings, the channelisation of players to regulated online gambling was 50.7 per cent in March 2023. 

Among black market sites, defined as those that offered content in German accessible with a German IP address without using a VPN, 28.9 per cent of traffic was to unlicensed providers based in the EU and 19.9 per cent to operators based elsewhere. The report estimates that three quarters of online gambling revenue is taken by the black market.