The German Sports Betting Association (DSWV), which represents the leading sports betting industry in the country, has highlighted a serious issue in the regulated gambling sector after recent market data was released. DSWV is urging immediate reforms to Germany’s gambling laws following the Joint Gambling Authority of the Federal States (GGL) publication of comprehensive industry statistics for 2024. According to the data, roughly 25% of all gambling in Germany is conducted through unlicensed operators, a figure DSWV argues likely underestimates the true extent of the black market.
President Mathias Dahms expressed alarm over the discrepancy between licensed and unlicensed operators, noting there are currently 11 unlicensed gambling sites for every one that is licensed. He stated, “This development is a warning signal. Illegal providers benefit from the fact that they can offer a much wider range of bets – especially in the area of particularly popular live betting and the number of sports and competitions that can be bet on. This is precisely why many users switch to these illegal sites.”
The GGL’s 2024 statistics show a notable increase in illegal German-language sports betting websites monitored by the regulator, rising from 281 in 2023 to 382, marking a 36% increase. In stark contrast, only 34 websites from 30 operators hold licenses and are included on the GGL’s official white list.
While GGL has made estimates of the unauthorized gambling market share, DSWV remains doubtful about these figures. The group cites independent studies, including the Schnabl report commissioned by DSWV and DOCV, suggesting the black market could represent over 50% of all gambling activity in Germany. Dahms stated, “At least a quarter of the market is illegal – this is clear, official confirmation that the black market has long been a serious structural problem and not a marginal phenomenon.” He added, “Anyone who wants to strengthen player protection must ensure that legal providers become competitive. Otherwise, it is precisely this protection that will be undermined by illegal offers.”
DSWV argues that the new figures from GGL underline the urgent need for a regulatory overhaul that would make the licensed gambling market more appealing to consumers. The association points out that licensed operators are facing stringent restrictions and should have the freedom to offer a wider array of products. In contrast to the black market, legal operators in Germany are burdened with strict compliance requirements, including mandatory identity verification, limits on bets, and access to the national player blocking system across operators.
Currently, a €1 maximum stake limit for online slots and industry-wide deposit limits are enforced by the Interstate Treaty. Players are restricted to a maximum of €1,000 in monthly deposits across all regulated platforms. In December 2023, an interim evaluation of the Interstate Treaty was initiated to assess the effectiveness of existing gambling regulations in Germany and to develop recommendations for potential improvements, some of which are expected to be implemented by federal states when amending the law this year.
Dahms remarked, “The legal market is safer today than ever before, with extensive measures to protect players. But if this market becomes less attractive due to overregulation, users will switch to illegal offers. Only those who create a reputable but also attractive offering can keep players in the legal market and effectively curb the black market.” He concluded, “The best protection against the black market is an attractive, legal offering. This includes more permitted types of betting, more live betting, and realistic regulation.”
