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GGL Stands by Data Collection Methods Amid Debate Over Germany’s Unlicensed Gambling Market Size



The Glücksspielbehörde (GGL), Germany’s newly established federal gambling regulator, has stepped forward to assert the validity of its data collection methods in estimating the size of the unlicensed gambling market. This response addresses recent concerns raised by trade bodies DSWV and DOCV, who suggested that a significant portion of gambling in Germany occurs within the black market.

In the midst of a heated debate, Germany’s GGL reaffirms the accuracy of its methods for gauging the unlicensed gambling market, amidst claims of an underestimated black market presence.

The issue of accurately measuring the illegal online gambling market has been contentious, with varying results from different studies. The GGL acknowledges this complexity and expresses its openness to scientific discourse and new approaches for data collection, emphasizing the evolving nature of its methodologies.

The integrity and accuracy of market data are crucial for effective regulation and policy-making in the gambling sector. By defending its approach, the GGL aims to ensure a comprehensive and reliable understanding of the gambling landscape in Germany, crucial for combating the challenges posed by unlicensed gambling.


Stakeholders in Germany’s gambling industry should stay informed about these developments. The discourse around market measurement methods is vital for shaping a regulated and responsible gambling environment in the country.

The GGL stands by its previous estimate that the market volume of unlicensed gambling lies between €300 million and €500 million, which is about 2 to 4 percent of the regulated market’s size. It estimates the presence of 800 to 900 unlicensed websites offering various forms of online gambling, including casino games, virtual slots, online poker, sports betting, and secondary lotteries.

Addressing industry criticism, the GGL firmly rejects the notion that its data collection for the illegal online gambling market is based on a static model, underscoring the complexity and dynamic nature of the black market. The regulator emphasizes that all collected data is estimated, offering a snapshot of the market at a specific time.

The debate over the size of the unlicensed gambling market was further fueled by independent research commissioned by the online casino association DOCV and the sports betting association DSWV. Conducted by economist Gunther Schnabl of the University of Leipzig, the study found that only 50.7 percent of players were channeled to regulated online gambling as of March 2023. The report also suggests that a significant portion of online gambling traffic and revenue in Germany is captured by black market operators, both within the EU and elsewhere.


As the GGL continues to refine its methods and approaches, the discussion around the size and impact of unlicensed gambling in Germany remains a crucial factor in shaping the country’s regulatory landscape and strategies for a safer and more responsible gambling environment.

Jerome, a valuable addition to the Gamingo.News team, brings with him extensive journalistic experience in the iGaming sector. His interest in the industry was sparked during his college years when he participated in local poker tournaments, eventually leading to his exposure to the burgeoning world of online poker and casino rooms. Jerome now utilizes his accumulated knowledge to fuel his passion for journalism, providing the team with the latest online scoops.

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