Since the implementation of the State Treaty on Gambling in 2021, Germany’s Joint Gambling Authority (GGL) has worked to create a secure and regulated gambling market. At the Gaming in Germany conference, Ronald Benter, GGL board member, presented data illustrating growth in the legal market while emphasizing GGL’s commitment to player protection, fair competition, and data-driven regulatory evolution. However, ongoing concerns about Germany’s black market and regulatory practices highlight the complex landscape the GGL must navigate.
Legal Market Growth and Regulatory Commitment
The GGL’s mission to enforce a stable regulatory framework is central to its activities. With licensing and supervision strategies aimed at fostering fair competition and safeguarding players, Benter emphasized the GGL’s role in stabilizing the market in line with the 2021 State Treaty. According to Benter, “A sustainably regulated, stable market with reliable framework conditions is essential to ensure a safe gambling environment for players.” He also shared plans for a comprehensive, data-driven evaluation of the treaty’s effectiveness, focusing on the impact of player protection measures and gambling advertisements.
The Black Market Dilemma
Despite these regulatory strides, the black market remains a significant issue. In response to concerns from industry stakeholders, Benter highlighted ongoing efforts to address illegal gambling, including a channelization study designed to measure the black market’s scope more accurately. This evaluation will inform future regulatory adjustments, with the GGL calling for active industry involvement to tackle these issues collectively.
Reports, including a Bayerischer Rundfunk documentary, indicate that foreign betting sites attract German consumers, potentially circumventing the GGL’s oversight. Trade bodies argue that black-market operators, rather than EU-regulated entities, pose the main threat. The GGL, in response, is committed to dialogue and collaboration with stakeholders to find effective solutions and close regulatory gaps.
Google’s Advertising Policy and Regulatory Alignment
Adding to the push for a regulated market, Google has updated its Gambling and Games policy, requiring that only licensed operators may advertise on its platform in Germany. Effective 25 September, this policy limits gambling advertising to GGL-accredited businesses, reinforcing the GGL’s efforts to restrict unauthorized gambling access. Google’s new rule underscores the importance of responsible gambling, with any violations resulting in ad removals or, in severe cases, account suspension.
A Path Forward
While the GGL reports that only 4% of the market is occupied by unlicensed online gambling, industry groups, such as the DSWV, have challenged this figure, claiming the black market accounts for half of all gambling activity. The DSWV continues to call for legislative changes, including adjustments to the country’s advertising ban, which they argue drives consumers to unregulated platforms. As the GGL remains open to dialogue with stakeholders, it emphasizes that these collaborative efforts are essential to balancing market growth, consumer protection, and competitive fairness.
The GGL’s approach demonstrates a commitment to data-driven reform, ongoing dialogue, and collaborative problem-solving in a complex regulatory environment. However, the challenges of black-market operators and evolving legislative demands underscore the need for adaptive, transparent regulation. As Germany’s gambling industry continues to develop, the focus remains on securing a safe, equitable, and legally compliant market for all.
