Germany wants to make black-market gambling unprofitable
Germany’s gambling regulator, the Gemeinsame Glücksspielbehörde der Länder (GGL), is tasked with overseeing cross-state gambling activity under the 2021 Interstate Gambling Treaty. In a recent annual report, it detailed a multi-pronged approach to fighting the black market that has led to hundreds of unlawful sites being blocked or taken offline.
The regulator’s approach is to “make the business model of illegal providers and advertisers unattractive through supervisory measures.”
“The GGL uses various means to take action against illegal gambling and the advertising for it,” the agency stated. “These include traditional administrative procedures with prohibition orders, which can be enforced through penalty payments. Measures such as payment blocking and network blocking are also used.”
In 2024, the initiated 231 prohibition procedures targeting illegal gambling operations and the advertising that promotes them. Of these, 83 procedures concerned both gambling and advertising, while 148 addressed advertising alone. The authority said that by the end of the year, 188 illegal online gambling providers had withdrawn their services from the German market.
Payment blocking proves effective
Payment blocking strikes at the heart of illegal gambling operations by cutting off the flow of money. Operators are deprived of revenue, while players begin to question whether they’ll ever see their winnings or deposits returned. The effectiveness of this tactic depends on the cooperation from payment service providers, something the GGL says improved last year.
“Through payment blocking measures, 43 of the payment service providers addressed by the GGL cooperated immediately and stopped their services for the affected illegal offerings. This affected offerings from 53 illegal gambling operators or 165 websites.”
Although some illegal platforms still displayed logos of well-known payment providers, the GGL found that alternative, mostly less known payment services was typically used instead.
Geo-blocking and the role of the Digital Services Act
While IP-based blocking of illegal websites remains legally complex in Germany, the GGL increasingly turned to Geo-blocking under the EU’s Digital Services Act. By contacting host providers directly, the agency was able to make 657 websites inaccessible from Germany.
“The GGL used the Digital Services Act (DSA) actively in 2024 and was able to make numerous sites inaccessible to players in Germany,” the report states.
Website blocking, however, remains a game of cat and mouse. Black market operators, well accustomed to this kind of enforcement, often duplicate their content and simply move it to a new domain. When illegal operators switched hosting services in an attempt to circumvent restrictions, “the GGL re-initiates the process with the current provider and takes appropriate measures.”
Pressure on tech giants
The GGL also reported progress in limiting the advertising reach of unlicensed operators, particularly through its work with Google. After months of dialogue, the tech company revised its advertising rules for gambling in Germany in September 2024.
“Since 25 September 2024, only providers with a valid German license are allowed to advertise their offering in German search results via Google Ads,” the regulator confirmed. The GGL noted a “clearly positive effect” from the change but said further steps were needed to combat “cloaking” and other forms of ad evasion.
Public participation and legal action
The GGL’s whistleblower system received around 8,000 reports in 2024, half of which concerned suspected illegal gambling. These tips, along with regular online monitoring, form the basis for many of the authority’s enforcement actions, the GGL explained.
Legal action is another key tool. The GGL was involved in 68 court cases last year related to enforcement measures. It also filed 23 criminal complaints. However, the agency expressed concern that “many German law enforcement authorities do not apply Section 284 of the Criminal Code to providers based abroad.” It has since called for an expansion of the law to address foreign operators, including some based in other EU countries, targeting German players.
Black market gambling in Germany worth an estimated €500–600 million
Despite progress, the GGL recognises that illegal operators continue to adapt. Many now offer crypto-based platforms or launch duplicate “mirror sites” under new domain names. According to the report, 212 unlicensed providers were detected operating 858 gambling websites, with estimated revenues between €500 and €600 million.
These figures represent approximately 3 to 4 percent of Germany’s entire legal gambling market, both land-based and online. However, unlicensed operators now account for around 25 percent of the market for so-called high-risk online gambling, which includes sports betting, virtual slot games, online poker, and internet horse betting, according to the GGL.
