Operators Challenge GGL Report Claiming 5% Growth

Germany’s gambling regulator claims the licensed market is growing—but industry insiders are raising red flags.

The GGL reports a 5% rise in gross gambling revenue in 2024, backed by enforcement actions and ad reforms.

Yet operators say the numbers don’t add up, pointing to flawed timelines, low channelisation, and underestimated black market activity.

As the regulatory debate intensifies, calls are growing for better data, transparency, and realistic reporting standards.

Reality Check: Operators Question GGL’s Reported Growth in German Gambling Revenue

Key Points

• GGL reports €14.4bn in licensed gambling revenue in 2024—up 5% year over year.
• Operators challenge the report, arguing black market figures are grossly underestimated and tax data contradicts claims.
• Critics cite low channelisation rates, with some studies suggesting only half of German players use legal platforms.

German Gambling Regulator Claims Market Growth, But Industry Voices Cry Foul

The Gemeinsame Glücksspielbehörde der Länder (GGL) has published its annual report for 2024, claiming the German licensed gambling market is growing steadily. According to the regulator, gross gambling revenue (GGR) rose by 5% to €14.4 billion, with tax and levy contributions hitting €7 billion, up from €6.6 billion the previous year.

The GGL attributes this growth to tighter enforcement against illegal operators, improved ad regulation—particularly Google’s revised policy—and enhanced monitoring tools. The report boasts over 1,700 websites reviewed, 231 prohibition cases launched, and 450 illegal sites blocked in Germany. An additional 657 platforms were geo-blocked using the EU’s Digital Services Act (DSA).

Yet many in the industry aren’t celebrating. Operators and experts alike are raising serious concerns about the accuracy, scope, and methodology of the GGL’s data.

Discrepancies Between Reported Growth and Ground Reality

Leading the criticism is Christian Heins, Director of iGaming at Tipico, who shared a detailed critique on LinkedIn. He questioned the GGL’s claim that the legal market grew substantially, pointing to falling tax revenues that contradict the reported rise in GGR.

“The reported figures for the legal online casino market are hard to reconcile with actual tax revenue, which has dropped significantly,” Heins wrote. “The numbers just don’t seem to add up.”

Heins also questioned the timeline of advertising improvements. The GGL credits Google’s September policy change for a drop in visibility of illegal ads. However, Heins asserts that December 2024 saw no such impact—figures merely returned to previous levels and remained flat until early 2025. The real decline, he argues, came only after systematic reporting efforts, not Google’s directive.

Black Market Figures Under Fire

Perhaps the most contested part of the report is the GGL’s estimate that unlicensed operators captured €500–600 million in GGR—roughly 3–4% of the market. The regulator also claims black market operators dominate 25% of high-risk segments like online slots.

Industry representatives strongly disagree. A 2023 University of Leipzig study, commissioned by trade bodies DOCV and DSWV, suggested that channelisation—the proportion of players using licensed platforms—hovered at just over 50%. Heins went further, estimating that the online casino black market alone could be worth €1.5–2 billion in GGR.

Such discrepancies reveal a deep disconnect between regulatory data and operator insights. Critics argue that by underestimating the black market, regulators may be misallocating resources and failing to address the root causes of illegal gambling demand.

GGL Defends Its Strategy, Cites Enforcement Wins

Despite the backlash, GGL CEO Ronald Benter defended the regulator’s approach. He highlighted the importance of court rulings, continued monitoring of advertising, and the development of safe servers to enable real-time market data collection.

“Our measures are having an impact,” Benter said. “But combating illegal offerings remains a long-term process that requires strategic and coordinated action.”

He reaffirmed the agency’s goal of making illegal gambling “economically unviable” through enforcement, cooperation, and technology-driven oversight.

Germany’s gambling market may be growing on paper, but the reality is far more complex. While the GGL’s 2024 report touts progress, operators on the ground are questioning the numbers and highlighting inconsistencies that paint a very different picture. From low channelisation rates to overlooked black market volume, the gap between regulation and reality appears to be widening.

As the market matures, transparent data, stakeholder dialogue, and independent auditing will be crucial to building trust in Germany’s iGaming framework. Otherwise, regulators risk mistaking statistical optimism for genuine progress—and the legal market may continue losing ground to its illegal counterpart.