GGL Pins Rate of Black Market Operations in Germany at 23%
GGL Pins Rate of Black Market Operations in Germany at 23%
Germany’s gambling regulator has put a number on what everyone suspected: nearly a quarter of the country’s online gambling market operates outside the law. The Gemeinsame Glücksspielbehörde der Länder (GGL) estimates channelization now sits at just 77%, meaning roughly 23% of player spending flows to unlicensed operators.
That translates to real money.
The black market pulled in an estimated €547 million in gross gaming revenue during 2024, up 17% from €466 million the previous year. While the regulated sector continues to grow, the illegal market is growing faster. And that’s a problem the GGL is once again urging lawmakers and stakeholders to address.
The Numbers Behind the Estimate
Measuring black market activity is never straightforward, granted. Unlicensed operators don’t file reports or publish figures, so regulators have to work from indirect data. The GGL commissioned research from the Blockchain Research Lab, which surveyed 2,000 online gamblers who’d been active in the past year.
Participants named up to seven platforms they’d used and provided details on stakes and losses. Researchers then cross-referenced those platforms against official licensing records to separate legal from illegal operations. They used additional tracking methods, behavioral panels, and proxy data to validate the findings and account for gaps in the methodology.
GGL CEO Ronald Benter defended the approach: “The scientifically calculated channeling rate confirms our previous assumptions about the size of the black market. The results support the fact-based regulatory approach within the framework of the 2021 Interstate Treaty on Gambling.”
Where Players Are Going
The research identified clear patterns in platform usage. Tipico, Bet-at-home, Betano, and Bwin ranked as the most popular licensed brands. On the unlicensed side, Stake.com, WooCasino, and PlatinCasino came up repeatedly in player responses.
Interestingly, average stakes per session didn’t differ much between licensed and unlicensed platforms. The gap appeared in losses. Players on unlicensed sites reported losing an average of €88.96 per session, compared to €77 on regulated platforms. That difference suggests either less favorable odds or more aggressive game mechanics on the black market side. Could be both.
What Comes Next
The GGL acknowledges no single measurement method captures the full picture. They’re calling for ongoing surveys combined with advanced monitoring tools, including machine learning and transaction analysis, to track unlicensed operators more effectively. Whether that’s enough remains to be seen.
The challenge for German regulators is straightforward: how do you compete with operators who don’t follow the rules? Licensed platforms operate under stake limits, advertising restrictions, and mandatory player protections. Unlicensed sites offer none of that friction. Until enforcement catches up with technology, that 23% will likely remain stubborn.
The 2021 Interstate Treaty on Gambling was meant to create a functional regulated market. Three years in, it’s delivered licensing and structure. What it hasn’t delivered is channelization rates comparable to more mature markets like the UK or Sweden, where legal operators capture well over 90% of activity.
Germany’s got the framework. Now it needs the enforcement muscle to make it work.
