Germany’s Federal Gambling Authority (Glücksspiel – GGL) has warned the federal states that the threat of illegal online gambling should be treated as a serious public health risk.
The warning was issued ahead of September 24, the annual Gambling Addiction Action Day. The regulator also urged state agencies to more closely monitor offers and advertising that promote unlicensed operators.
As Ronald Benter, CEO of the GGL, explained: “Illegal platforms do not offer effective player protection mechanisms. Anyone who plays there runs a significant risk of developing a gambling addiction.”
The Action Day is held under the patronage of Professor Hendrik Streeck, the Federal Government’s Commissioner for Addiction and Drugs, and in 2025 carries the motto: “Gambling Harms – Recognise, Name, Avoid.”
This year’s campaign includes a symposium for state authorities to exchange best practices in treating gambling addiction. Consumers are also reminded to consult the “whitelist” of licensed operators under the Fourth Interstate Gambling Treaty (GlüNeuRStV).
Professor Streeck, speaking as patron of the campaign, presented figures showing that 1.3 to 1.4 million adults are already addicted, while a further 3.5 million are at risk. Around 600,000 minors live with at least one gambling-addicted parent, facing neglect, depression, anxiety, and financial insecurity. Streeck stressed that gambling addiction remains one of the most common forms of addiction in Germany, often hidden for years and devastating for families.
However, these figures conceal deeper problems: experts have no unified approach to measuring gambling-related harm. There is also no academic consensus on how to separate play on licensed and unlicensed sites, or how to assess the true social costs.
Almost three years after the 2021 State Treaty on Gambling (GlüStV) came into force, the federal system still faces problems: disputed data and the strong presence of the black market.
In its Third Annual Activity Report, the GGL stated that unlicensed operators accounted for about 25% of the online market in 2024. Official figures recorded legal stakes of €8.2bn, up from €7.9bn the previous year.
For the German Sports Betting Association (DSWV), this was a step toward transparency but not accuracy. Its Chairman, Mathias Dahms, said the black market share is much higher, “exceeding 50%,” citing research including the Schnabl report.
The trend is worrying: the number of illegal German-language betting websites rose by 36% in one year – from 281 to 382 – while the GGL’s whitelist contained only 34 licensed sites.
“The ratio of legal to illegal sites is around 1 to 11,” Dahms said. “Illegal providers benefit from offering wider markets, especially in live betting, which is immensely popular. This is precisely why many users switch.”
The dispute reflects a broader question over Germany’s restrictive model. Licensed operators are bound by stringent rules including €1 maximum stakes on online slots, strict deposit caps, narrow bet types and heavy ad restrictions.
Critics argue that these restrictions make the legal market less appealing. By contrast, illegal sites exploit demand for in-play betting and broader wagering options.
This gap undermines channelisation, the treaty’s core goal of steering players into the regulated market. Critics say that since GlüNeuRStV’s inception, true accountability has been paused, with conflicting statistics fuelling a stalemate between regulator and industry.
The GGL, for its part, has pressed ahead with enforcement. Since 2023 it has implemented geo-blocking under the EU Digital Services Act, expanded payment blocking, and lobbied Google to restrict ads to licensed operators. But enforcement is resource-intensive: by late 2024 the GGL was defending 189 lawsuits, many brought by operators challenging licence decisions and restrictions.
The regulator leans heavily on the GlüNeuRStV Atlas compiled by the University of Bremen, but these figures are refuted by the German Online Casino Association (DOCV), which argues they understate the black market and misrepresent consumer behaviour.
Underlying these disputes is a constitutional reality: the GGL enforces, but cannot legislate. Any reform – whether on advertising, sponsorship, deposit limits or product scope – requires Bundestag approval, and political opinion remains divided.
Betting on amateur football has already triggered state-level disputes over integrity and oversight, while also prompting operators like Interwetten to pull wagering markets on amateur sports.
Looking ahead, 2026 is expected to bring a federal law on gambling advertising and sponsorship, likely the next battleground. Until then, both sides invoke player protection: the GGL through uniform restrictions, and the DSWV by demanding a legal market strong enough to outcompete the black market.
As Dahms put it: “With this figure, the GGL is creating more transparency for the market and the public. Fact-based debates are only possible if we have access to reliable official figures – we expressly welcome this step.”
Clarity has not yet delivered consensus. Germany’s online gambling market remains a divided house, with addiction concerns, black market leakage, and regulatory rigidity leaving the future of the Interstate model uncertain.
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