A key study of German online gambling behaviours, views engagement with the black market as an ‘embedded symptom’ of Interstate liabilities. However, the GGL maintains that liabilities are no grounds for a review of the Interstate regime limiting the offering of licensed operators.
Glücksspielbehörde (GGL), the Federal Authority of Gambling in Germany, has flagged ‘structural liabilities’ of the Fourth Interstate Gambling Treaty (GlüStV 2021) impacting the channelisation rate of the market against illicit operators.
The observation forms part of the GGL’s study titled “Investigation of the Black Market and Channelling of Online Gambling” – the Authority’s long-awaited research on the Interstate market’s exposure to unlicensed gambling.
The black market report is one of three studies conducted on behalf of the GGL to support the forthcoming 2026 joint review of the GlüStV regime, five years following its federal launch in 2021.
Additional studies will be published on advertising recommendations and an assessment of player protections.
“This study provides one of the most detailed behavioural insights to date on Germany’s online gambling market, offering a critical evidence base for assessing whether the Interstate Treaty has achieved its core objective of channelising players into the regulated system.”
The headline findings of the 2024 study undertaken by Blockchain Research Lab on behalf of the GGL point to the “channelling rate of unregulated online gambling” standing at 23%, as the Interstate regime maintains revenues generated by licensed operators of 77%.
Of significance, the findings dismiss previous analysis of the federal authority, which had relayed in its 2025 report to the Bundesländer that the Interstate channelling rate was 95% effective – a figure immediately rejected by German gambling firms and trade bodies.
No conclusive view of GlüStV regime
Researchers undertook a survey of 2,000 online gamblers who had engaged with a reported 4,027 online brands (legal and illegal). Data captured player activity, including monthly spending, losses and frequency of online gambling.
Audiences are reminded that researchers could not model an accurate sample pool of German consumers engaged with the GlüStV regime.
As such, feedback focused on active online gamblers. The report reflects that its “results cannot be generalised as a condition of the Interstate market”.
Focusing on respondents’ engagement, the survey found that its sample pool of players reported participation with 20% of unlicensed operators.
Monitoring activities (gambling frequency) revealed that 22.4% of total player stakes were placed with black market operators. The report further detailed that its sample of players had lost 23% of total losses to unlicensed websites.
The figure corresponds to circa €550m of gambling income being lost to the black market in 2024, as the segment is believed to now be “no longer marginal but structurally embedded” in German gambling.
The black market figure reflects a significant dent on GGL data, which detailed online gambling GGR of €3.6bn in 2024 (total market size of €14.4bn including lotteries and land-based gambling).
Disconnect for high value players
Observations point to “structural tensions” in player protection which limit market attractiveness, as cited: “Germany’s regulatory framework reveals a clear structural tension: measures designed to protect players are simultaneously constraining the competitiveness of licensed operators, creating conditions in which high-value activity continues to migrate to unregulated markets.”
Though not pinpointed, the stringent restrictions reducing competitiveness are most likely to be the universal €1,000 per month deposit limit and the €1 stake limit on online games.
Further breakdown of player behaviour provides a clearer signal as to where the Interstate regime is losing ground.
The survey highlights that users engaging with unlicensed operators demonstrate higher average monthly spend and greater intensity of play, indicating that the black market is not simply capturing casual activity, but attracting high-value and high-frequency players.
Researchers note that this migration is not incidental, but reflective of deliberate player choice, as consumers seek fewer restrictions, higher limits and more flexible product offerings than those permitted under the GlüStV framework.
In this regard, the black market appears to benefit from a concentration of premium play, amplifying its economic weight beyond headline participation figures.
“Efforts to curb the black market must not come at the expense of player protection; instead, authorities face the challenge of enforcing existing rules while maintaining a competitive and attractive regulated market.”
GGL focus remains on enforcement
While the study stops short of recommending legislative reform, the GGL acknowledges that its findings provide clear grounds for enhanced enforcement coordination against unlicensed operators.
Key recommendations note: “The findings underline that the black market cannot be contained through regulatory design alone, but requires consistent and effective enforcement against unlicensed operators targeting German consumers.”
The Authority maintains that the structural conflict between player protection and channelisation cannot be resolved through deregulation alone, and instead requires a more assertive supervisory and enforcement approach.
This includes strengthening direct enforcement via payment and internet service providers, and extending cooperative campaigns with international regulatory counterparts.
“We are in discussions with the states regarding the extent to which the results of this study may necessitate adjustments to the legal requirements,” said Ronald Benter, Co-President of the GGL.
“Furthermore, we are awaiting the results of the currently ongoing study on online player protection.”
No grounds for reform
Yet, as attention turns to the 2026 evaluation of the Interstate Treaty, the GGL stops short of translating its most direct acknowledgement of structural liabilities into a case for reform.
While the findings represent the clearest recognition to date that the GlüStV framework is failing to fully channel demand into the regulated market, the Authority provides no formal recommendations or proposed interventions to improve channelisation outcomes.
The GGL instead reiterates its limited remit, noting that it is “monitoring the evaluation process of the GlüStV 2021 by the federal states” and that its contribution is confined to evidence gathering.
As outlined, the Authority’s role is to “provide data and analysis on player protection, advertising and the black market, and highlight where adjustments may be required”, rather than to prescribe legislative change.
This position was reinforced by Co-President Ronald Benter, who stated: “We are in discussions with the states regarding the extent to which the results of this study may necessitate adjustments to the legal requirements.
“Furthermore, we are awaiting the results of the currently ongoing study on online player protection.”
Whether the Bundesländer will act on what is now a clearly evidenced set of structural tensions remains the defining question ahead of 2026, as Germany’s regulatory model faces increasing scrutiny over its ability to balance player protection with sustainable channelisation.