Key Points
- The GGL wants greater professional discretion within the GlüStV 2021 framework, arguing that even agreed-upon changes can take several years to clear the interstate process.
- Separately, the authority wants legislators to enable criminal proceedings against people offering illegal gambling from abroad, a step that has “almost never happened” in five years of the GGL’s operation.
- The GGL’s 77.03% channelisation estimate, drawn from a survey of 2,000 gamblers, is disputed by multiple competing analyses, including an above-80% illegal share for virtual slots referenced by a Hessian Fiscal Court.
Five years ago, Germany had no unified online gambling regulator. Today, the Gemeinsame Glücksspielbehörde der Länder (GGL) oversees 129 licensed operators and intermediaries across 229 authorised gambling websites. Now it wants to change how it operates, and the request it is placing before Germany’s 16 federal states is more precise than a simple demand for more power.
Two Different Requests Inside One Reform Push
The GGL is using the ongoing evaluation of the 2021 Interstate Treaty on Gambling to press for two things that are fundamentally different in nature.
The first is greater professional discretion within the existing legal framework. Executive board member Ronald Benter, speaking to the Mitteldeutsche Zeitung on September 22, did not qualify the central problem: “The illegal market is very dynamic. That is why we, as an authority, have to become faster, too.”
The current treaty ties the GGL to a consensus-based governance process spanning all 16 states. Even when the regulator and the states agree that change is needed, amending the treaty can take several years. The GGL wants more room to act on market shifts within the existing rules. Decisions would be coordinated through its administrative board, where the states hold representation.
“Ultimately, we have the expertise and should therefore also be able to react faster to developments and decide on new measures,” Benter said.
The second request is different in kind and in what it actually requires. The authority wants legislators to create a route for public prosecutors to pursue criminal cases against people who operate illegal gambling platforms targeting German users from abroad. Benter acknowledged this has “almost never happened” in five years of the GGL’s existence. This goes beyond administrative discretion; it requires a legislative change extending the reach of criminal law to foreign operators.
What Five Years of Enforcement Has Built?
Since becoming fully operational in January 2023, the GGL has built a substantial enforcement record. Prohibition proceedings rose from 68 in 2022 to 287 in 2025. By the end of 2025, around 1,843 illegal websites were no longer accessible in Germany through prohibition or network blocking. The authority has also moved beyond licensed operators, targeting payment providers, advertising partners, affiliate networks, and hosting companies that enable illegal sites.
It speaks to real institutional growth because, before 2021, there was no centralised national regulatory body for gambling in Germany; this structure has already started operating and extending its jurisdiction each year since then.
The Frankfurt Investigation and What It Showed About Enforcement Limits
The raids took place on 8th September 2026, involving 11 premises within the Rhine-Main region. More than 100 police personnel took part in the coordinated raids. In this regard, five persons have been accused of running a number of illegal gambling websites starting from July 2021. From the reports of the investigation, it is alleged that €5.86bn in stakes were placed via the sites in question from July 2021 to December 2023. An estimated value of assets worth €82m has been seized, bank accounts were blocked, and one person was arrested.
The GGL welcomed the outcome, noting it had shared enforcement data with prosecutors, including findings from payment blocking and advertising investigations. It used the Frankfurt result to renew its public call for greater criminal law action against illegal operators.
German industry bodies cited the alleged stake volumes as evidence that the black market exceeds official estimates. Worth noting is that the €5.86bn figure represents total stakes across 30 months, not gross gaming revenue for a single year; those are different measures covering different periods, and the comparison does not translate directly into a market-share calculation.
The 77% Channelisation Figure at the Centre of the Debate
The GGL’s channelisation study, commissioned from the Blockchain Research Lab and published in March 2026, estimated the regulated market’s share at 77.03% for 2024. The study drew on a self-reported survey of 2,000 people who had used online gambling products in the previous twelve months. Based on that sample, it estimated the illegal market’s gross gaming revenue at approximately €547m for 2024, up from a prior-year estimate reported in the Blockchain Research Lab study. The methodology relies on players’ self-reported gambling behaviour rather than direct market measurement.
Competing analyses have consistently placed the unregulated share considerably higher. The German Online Casino Association cited Nielsen data putting the illegal share at 56%. A study commissioned by the DSWV and DOCV from the University of Leipzig, using traffic and survey methodology, recorded channelisation at just 50.7% as of March 2023. A separate Sport1 and Handelsblatt Research Institute analysis found the illegal share above 50% overall. For virtual slots specifically, a Hessian Fiscal Court referenced an above-80% illegal share estimate in proceedings that drew on that analysis.
The DSWV has counted 382 illegal German-language sports betting websites operating against just 34 legal ones. That access imbalance helps explain why the competing estimates diverge so substantially from the GGL’s survey-based figure.
What Germany’s First Rule Relaxation Already Showed?
Before the treaty review concludes, the GGL already offered a concrete preview of greater discretion in action. Effective July 1, 2026, Germany’s online slot stake limit moved from a flat €1 per spin to a tiered system, with a new ceiling of €5 available to players with a clean 90-day gambling history. Adults aged 21 and over now qualify for stakes up to €3 per spin; those under 21 remain at €1.
It was the first time the GGL exercised its treaty authority to adjust stake limits in response to market conditions. DOCV managing director Priglinger-Simader argued the previous flat cap had been pushing players toward offshore platforms where German player protections simply do not apply.
Deposit limits represent the remaining unsettled question ahead of the year-end deadline. The current €1,000 monthly cap, with higher thresholds available to screened players, requires a fresh decision before existing guidance expires. Two previous amendment drafts failed to gain majority approval, and a third is expected shortly. That deadlock illustrates precisely the kind of multi-state negotiation the GGL says it needs to move beyond.
Expert Analysis
We find this a genuinely complicated regulatory moment, and the channelisation data is at the heart of why.
The 77.03% figure is being asked to carry considerable policy weight. In our view, a self-reported survey of 2,000 gamblers is a useful signal but not a definitive national market measurement. Multiple independent analyses, using different methodologies, have produced substantially lower channelisation estimates. A Hessian Fiscal Court’s reference to an above-80% illegal share for virtual slots reflects a picture quite different from the GGL’s headline number. The methodology behind 77.03% deserves more scrutiny than it has received in the policy debate so far.
We also think the GGL’s two requests deserve separate evaluation rather than being treated as a single package. The case for faster internal decision-making within the existing framework is largely administrative, and the argument for it is clear. The case for criminal proceedings against foreign operators is a legislative question with real cross-border complexity that the treaty review alone cannot fully resolve.
Both requests rest on the assumption that the illegal market is as large and as dynamic as the GGL says it is. Until Germany has a more reliable method of measuring that market, the 16 states deciding on these changes are working with limited and contested evidence. That is the conversation the year-end treaty review needs to take seriously.
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