SBC News Voice of the Sports Betting Industry
Online gambling stakeholders in Germany remain split over the data insights of the Fourth Interstate market and its actual exposure to black market threats.
Nearly three years since Germany’s Fourth Interstate Gambling Treaty (GlüStV 2021) came into force, the federal online gambling regime remains troubled by divisions on data, activity and trends.
The Joint Gambling Authority of the German States (GGL), which assumed full oversight in 2022, has released its Third Annual Activity Report for 2024, and the results reveal as much about persistent structural tensions as about progress.
For the first time, the GGL has published concrete figures on both the volume and character of Germany’s online betting market. Legal gambling operators generated €8.2bn in total stakes in 2024, a modest increase from €7.9bn the previous year.
But the more controversial figure was its estimate that unlicensed operators account for roughly “25% of the total market for online gambling” including sports betting, virtual slot machines, and poker.
The data represent an improvement in transparency, and was cautiously welcomed by the German Sports Betting Association (DSWV), which has long lobbied for more accountability and disclosure.
“This is clear, official confirmation that the black market has long been a serious structural problem and not a marginal phenomenon,” said Mathias Dahms, Chairman of the DSWV.
Disputed ratios
The DSWV was quick to question the figures themselves. According to studies it commissioned including the influential Schnabl study — the actual black market share may exceed 50%, far above the GGL’s 25% estimate. This divergence reflects not just a disagreement over numbers, but over the nature of Germany’s regulatory strategy.
The trade body argues that the official data obscures the scale and speed of illegal growth, particularly in sports betting. One statistic stands out: the number of illegal German-language sports betting websites increased from 281 to 382 in a single year — a jump of 36%.
In contrast, only 34 licensed websites were listed on the GGL’s official whitelist. “The ratio of legal to illegal sites is around 1 to 11,” said Dahms. “Illegal providers benefit from the fact that they can offer a much wider range of bets—especially in the area of live betting, which is immensely popular. This is precisely why many users switch to these sites.”
These concerns are grounded in the reality of Germany’s highly restringing regulatory model. The DSWV claims that overbearing iGaming regulations, including strict caps on advertising, heavy limitations on live betting and bet types, and low deposit limits have simply made the legal market uncompetitive and structurally less appealing. “The legal market is safer today than ever before,” Dahms adds, “but if it becomes less attractive, users will migrate to illegal offers.”
GGL plays enforcer not lawmaker….
The GGL, for its part, is pressing ahead with its enforcement mandate. Since its operational launch in January 2023, the regulator has rolled out geo-blocking measures under the EU’s Digital Services Act, stepped up payment-blocking enforcement, and launched prohibition proceedings against illegal operators and their advertisers.
The authority also successfully lobbied Google to restrict gambling ads in Germany to licensed providers only, curbing one of the most visible channels for unregulated competition.
However, the GGL’s legal footing is far from stable. As of December 2024, the authority was embroiled in 189 lawsuits — many of them brought by operators contesting licensing decisions, technical restrictions, and advertising bans. These lawsuits absorb considerable resources and reflect broader discontent among industry stakeholders about the rigidity of the current system.
While the GGL is limited by statute to enforcement, it has acknowledged the need for reform. Its 2024 report indicates that recommendations on advertising policy will be shaped by ongoing academic research led by the Public Health faculty of the University of Bremen. The research will inform future proposals balancing player protection with market accessibility. This is the GGL’s preferred route: science-guided, cautious, and consistent with its public health mandate.
Political fault lines
But reform cannot come solely from regulators. In Germany’s federalised legal system, gambling laws operate across overlapping state and national jurisdictions. Any substantive overhaul of the legal framework—including changes to bet offerings, deposit limits or sponsorship guidelines—would need to pass through the Bundestag, Germany’s federal parliament.
This structural reality has led to deepening political debate. Most prominently, controversy has erupted around betting on amateur sports, particularly in football. While some states and operators support permitting such bets under tight supervision, others argue this could invite manipulation and undermine integrity. These debates feed into broader questions over which level of government—federal or state—should define the rules of the game.
Interstate on a diverging path
In 2026, Germany is expected to table a federal law on gambling advertising and sponsorship, which will almost certainly become the next battleground. Stakeholders are already jostling for influence, as the legislation could recalibrate how GlüStV 2021 is interpreted, enforced, and evolved.
In the meantime, both sides claim to be guided by player protection. But their definitions differ. The GGL sees protection as enforcement of uniform, restrictive measures; the DSWV sees it as offering a safe but attractive legal alternative to the black market.
There is, at least, a shared belief in data. “With this figure, the GGL is creating more transparency for the market and the public,” said Dahms. “Fact-based debates… are only possible if we have access to reliable official figures—we expressly welcome this step.”
But clarity has not yet delivered consensus. The GGL remains a strong administrative presence, but its inability to initiate legislative change leaves it vulnerable to political drift. The DSWV, meanwhile, continues to warn that inaction on reform will strengthen the very market that regulation was designed to suppress.
Whether the next phase of German gambling policy results in modernisation, fragmentation, or mere inertia will depend less on enforcement—and more on whether the country’s legislators are willing to match regulation to market reality.
