In Germany, the regulation of online gambling is struggling to contain the growth of the black market. According to the 2023 report by the Gemeinsame Glücksspielbehörde der Länder (GGL), illegal financial flows account for between 2% and 4% of gross gaming sales (GGR), or €400-600 million. But statistics shared at Gaming in Holland 2025 show that 80% of revenues go to illegal operators.
Differing estimates: a divide in the figures
The GGL claims that the regulatory apparatus is working: out of 1,864 sites examined, 133 were blocked and 438 cases dealt with, with 63 illegal operators being closed down. According to the authority, this demonstrates a firm commitment to restricting illegal supply.
Some operators and studies question this clarity:
- DOCV and DSWV argue that the rate of channeling to the legal market is grossly underestimated, citing a black market of 20% or more for online games.
- A study by the University of Leipzig reveals that in March 2023, only 50.7% of online gamblers were using regulated platforms; 28.9% were turning to non-EU-licensed sites, and 19.9% to offshore platforms.
- An analysis by Yield Sec estimates the black market’s share of online gambling at almost 47%, reporting more than 1,380 illegal operators, 45% of whom were also using official affiliates.
- At Gaming in Holland 2025, shared figures show that 80% of online gambling market revenues belong to illegal operators.
Why so much discrepancy? Opposing methodologies
- GGL figures: based on the global GGR – including land-based casinos – and based on visible legal and financial barriers.
- University and association studies: based on players’ behaviour (time spent, web traffic), the constraints of the legal offer (maximum stake of €1, waiting period, limited bonuses) push people towards illegality.
The differences concern the definition of the ‘black market’ and the measurement indicators: overall financial figures on the one hand, browsing and the attraction of more favourable offers on the other.
A rigid but inappropriate regulatory framework?
Since the Federal Treaty of 2021 came into force, the landscape has been highly regulated:
- Wagering limit: €1 per spin
- Limited monthly deposit: €1,000
- Tax on legal gaming turnover: 5.3%
- Technological blocks, bonus bans, very restricted advertising
These constraints have encouraged some players to turn to underground sites offering more generous bonuses, higher stakes or no-limit browsing.