Germany’s regulated online casino sector faces renewed scrutiny over black market estimates, with the country’s leading trade association firmly rejecting the regulator’s latest figures as fundamentally flawed. The dispute centres on whether Germany has successfully corralled three quarters of its players into licensed channels, or whether unlicensed operators still command roughly half the market.

The Glücksspielkollegium (GGL) published a comprehensive 120-page assessment last week claiming channelisation reached 77% in 2025. The figure comes from surveying 2,000 individuals who had gambled online during the preceding twelve months, excluding lottery products. Respondents were asked directly whether they had used illegal operators during that period.

Simon Priglinger-Simader, vice president of the Deutscher Online Casinoverband (DOCV), dismissed the methodology outright. “The numbers are not consistent with the observed tax numbers we know,” he stated, pointing to what he called non-representative sampling and recall bias inherent in asking survey participants about illegal activity.

Competing Assessments Point to Vastly Different Markets

The trade body maintains its November 2023 analysis, which placed black market participation at approximately 50%, remains the more accurate baseline. That study, authored by University of Leipzig economist Gunther Schnabl, used Nielsen gambling activity data combined with stakes flowing to unlicensed operators.

Priglinger-Simader argues the GGL’s estimated €547 million in black market gross gaming revenue for 2024 dramatically understates reality. “We think the actual turnover of illegal operators is much higher because of the massive number of bonuses, the lack of player protection, no loss limits, no spin limits, nothing at all in the black market,” he explained.

Licensed operators have reportedly received direct feedback from customers who migrated to unlicensed sites specifically to circumvent the regulated market’s stringent verification procedures and spending restrictions. Priglinger-Simader acknowledged this anecdotal evidence lacks the rigour required for formal inclusion in research analysis, though.

Updated Assessment Due This Summer

Professor Schnabl is currently preparing refreshed figures covering 2025, expected to surface between June and July. The update will incorporate an expanded catalogue of unlicensed operators serving German customers, reflecting what Priglinger-Simader described as a highly dynamic landscape that has shifted considerably over recent years.

The timing carries real significance given Germany’s ongoing review of its Interstate Treaty regulations. Licensed operators view this legislative examination as their primary opportunity to secure relief from contentious restrictions, including mandatory deposit caps and per-spin stake limitations.

Priglinger-Simader expressed concern the GGL might use its optimistic channelisation figures to resist regulatory reform. “They could use this to say everything is working perfectly fine, and they don’t have to do anything to strengthen the legal frameworks,” he cautioned. That scenario would leave licensed operators working under the same constraints that many argue drive players toward unlicensed alternatives.

Regulatory Progress Amid Persistent Disagreement

Despite his fundamental objections to the latest data, Priglinger-Simader noted one encouraging development. The GGL’s revised estimate represents substantial movement from its June 2024 position, when the regulator suggested the black market comprised merely 4% of overall activity.

That the figure has climbed to 23% in official assessments suggests growing regulatory acknowledgement of unlicensed competition, even if the trade body considers the adjustment insufficient.

The Interstate Treaty review is scheduled to conclude next year, setting up a real test of whether data disputes translate into meaningful policy adjustment. For Germany’s licensed sector, the stakes extend beyond academic debate over methodology. The outcome will determine whether the regulatory framework evolves to compete more effectively with unlicensed alternatives, or whether current restrictions remain locked in place despite persistent industry concerns about their market impact.

What the team thinks

Sheena McAllister says:

The tension between the GGL and industry over channelisation rates highlights a familiar regulatory challenge: measuring black market activity is notoriously difficult, and the methodology matters enormously. From a compliance perspective, if Germany’s licensed operators are genuinely capturing 77% of the market, that would be a remarkable achievement compared to other recently regulated markets, but the industry’s scepticism suggests the data sources may not be capturing the full picture of unlicensed activity. Getting these figures right isn’t just academic, it directly impacts whether current regulations are deemed fit for purpose or need adjustment to improve competitive parity with unlicensed sites.