The Deutscher Online Casinoverband (DOCV), Germany’s online casino association, has raised concerns over the recent update from the Gemeinsame Glücksspielbehörde den Länder (GGL) on the state of the country’s regulated gambling market. The DOCV argues that the regulator has significantly underestimated the scale of the black market.
In an interview with iGamingBusiness, Simon Priglinger-Simader, DOCV vice president and Entain regulator affairs council, criticized the GGL’s estimate that the black market holds a mere 4% market share. According to the GGL, the black market is valued at EUR 600 million, compared to the legal market’s EUR 3 billion. This would imply a market share of about 20% for illegal operators, which Priglinger-Simader contends is a significant issue.
A 2023 study commissioned by the DOCV and the Deutscher Sportwettenverband (DSWV), authored by Dr. Gunter Schnabl, suggested that only 50.7% of players were gambling within the regulated online sector. Conversely, 49.3% were using unlicensed EU providers or illegal offshore websites.
GGL to update figures
Other industry stakeholders have also noted the discrepancy and questioned the GGL’s report. The GGL is expected to release updated estimates soon, but the initial unrealistic figures have not been well received by the regulated sector.
Priglinger-Simader told iGB that the industry eagerly awaits the GGL’s revised estimates on the size of the black market, describing it as an “important and interesting step forward.”
However, the final GGL evaluations are likely to face delays. Originally scheduled for publication in 2026, the final report is now expected no earlier than 2027, given that the June update was already six months late, as noted by the DOCV.
Priglinger-Simader emphasized the need for the regulator to implement anti-black market measures sooner rather than later to prevent illegal operators from thriving unchecked.
He acknowledged the challenges faced by the GGL and commended its efforts to regulate the market. He suggested that lower tax rates and less restrictive regulations could enhance the competitiveness of the legal market. Despite the challenges, Priglinger-Simader remains optimistic about the gradual growth of the legal market.
