GGL says the illegal market GGR grows, but tracking methodology improves

The German iGaming market has been struggling with its channelization, with private groups arguing that the share of the illegal gambling market is larger than what the regulator, GGL, claims. These arguments continue with mutual accusations of flawed methodology, but GGL’s latest report has shown that the gross gaming revenue for the illegal gambling market continues to expand.

In 2024, black market operators generated €547m in GGR, up from €466 million in 2023, with the GGL acknowledging the trend. However, where the market remains fairly steady is the overall channelization rate - around 77.03% of all German gamblers stick to regulated options. The exact methodology is not perfect, as the GGL has relied on survey data, traffic data, and other relevant benchmarks to arrive at an estimate of what the illegal gambling market may be like. The debate over whether Germany's black market is 23% or 60% misses the more important point: it is growing, not shrinking. The GGL's own figures show black market GGR rising 17% year-over-year, from €466 million in 2023 to €547 million in 2024. Enforcement is clearly not keeping pace — 231 prohibition proceedings in 2024 against a market the regulator itself acknowledges runs to hundreds of illegal websites. The path to genuine channelization is not more enforcement alone. It is making the licensed market more competitive. Germany needs to revisit its stake limits, its bonus restrictions, and the overall user experience gap between licensed and unlicensed operators. Until the legal product is genuinely attractive, players will vote with their clicks. This conclusion comes only six or so months after the DSWV argued that the illegal gambling market and operators outstrip the regulated market at a rate of 11:1. Therefore, the trade group may also be skeptical about the newly suggested results, which pin the black market at only around 23% of the total. Whether this is possible is still subject to speculation. The most recent survey took input from 2,000 users who said they had played at a gambling brand, with the survey also looking into what brands were the most popular and what the average player loss was.

The survey indicated that 22.4% of total bets and 22.97% of total losses were generated through offshore (non-licensed companies), with the average monthly stakes at these platform amounting to €1,425 and the losses - to €475. This was noticeably higher than the average losses player experienced in the regulated sector - €358 and an average of €1,243 spent. The report put forward by the GGL and Blockchain Research Lab have taken into account technological solutions such as machine learning, cryptocurrencies, traffic and behavioral data, acknowledging the need to leverage cutting-edge technology to better and more accurately track