Germany's Black Market Problem Is Bigger Than Regulators Admit
Germany's gambling regulator claims 77% of players are in the licensed market. The industry says the real figure is closer to 50%, and the consequences of getting it wrong could reshape the country's entire regulatory future.
- DOCV Vice President Simon Priglinger-Simader has publicly dismissed the GGL's 2025 channelisation figure of 77%, calling the methodology flawed and the results too conservative
- Priglinger-Simader believes the real channelisation rate sits closer to 50%, pointing to the DOCV's own 2023 study by economist Gunther Schnabl as a more reliable benchmark
- The GGL's survey relied on 2,000 players self-reporting illegal gambling activity, which the DOCV says introduced recall bias and non-representative sampling
- The GGL estimated black market GGR at €547 million in 2024, but the DOCV argues the true figure is significantly higher given the absence of any player protections on illegal sites
- An updated Schnabl report using 2025 Nielsen data is expected around June or July, which could reignite the debate ahead of Germany's Interstate Treaty review
Germany Is Sitting on a Black Market Time Bomb While Its Regulator Looks the Other Way
Germany's gambling regulator, the Gemeinsame Glücksspielbehörde der Länder (GGL), published a landmark 120-page report last week claiming that 77% of online gamblers in Germany are now operating within the licensed market. On the surface, that sounds like a regulatory success story. But the country's leading online casino trade body isn't buying it, and they have the data to back up their scepticism.
Simon Priglinger-Simader, Vice President of the Deutscher Online Casinoverband (DOCV), has come out swinging against the GGL's methodology, arguing the regulator's survey design was fundamentally compromised from the start. The GGL chose to survey 2,000 individuals who had gambled online in the past 12 months, asking them directly whether they had used illegal operators.
Priglinger-Simader has pointed to two core problems with that approach. First, he argues the sample failed to capture the segment of the market most likely to be using black market sites, meaning the most relevant players were structurally absent from the data. Second, he notes that players are unlikely to honestly admit to participating in illegal gambling when asked directly, introducing significant recall bias into the results. He has also stated that the figures are inconsistent with observed tax revenue data, adding a further layer of doubt over the regulator's conclusions.
The DOCV is not working from guesswork here. Back in November 2023, the trade body commissioned its own independent study from Gunther Schnabl, a respected economist at the University of Leipzig. That study, which used gambling activity data sourced from Nielsen, concluded that up to half of all online gamblers in Germany were using illegal sites. Three years on, Priglinger-Simader maintains that figure remains far more accurate than anything the GGL has produced.
The regulator's own black market GGR estimate of €547 million for 2024 also draws sharp criticism from the DOCV. He argues the actual revenue flowing to illegal operators is considerably higher, pointing to the structural advantages those sites hold over their licensed rivals. Black market operators offer generous bonuses, face no loss limits, no spin limits, and operate entirely free of the player protection obligations that licensed sites must comply with. That is a compelling proposition for a certain type of player, and Priglinger-Simader says licensed operators are feeling it directly, with some even receiving messages from customers explaining they have moved to unlicensed sites specifically to escape Germany's strict regulatory framework.
That last detail is damning. When players are voluntarily choosing to leave the licensed market and telling operators about it, the scale of the problem becomes very hard to ignore.
A fresh Schnabl report is now in the works, expected to land around June or July 2026. It will incorporate updated 2025 Nielsen panel data and a revised list of illegal operators actively targeting German players, a list that has changed substantially over the past two to three years given how dynamic the black market has become.
The timing of that report matters enormously. Germany is currently in the process of reviewing its Interstate Treaty regulations, the legal framework that governs the licensed gambling market. That review is the industry's only realistic opportunity to push for meaningful changes to deposit limits and slot stake restrictions. If the GGL can point to its own 77% channelisation figure and argue the market is functioning well, the pressure to reform weakens significantly.
The DOCV has warned publicly that the regulator could use the data to argue everything is functioning as intended, removing any obligation to strengthen the licensed framework. It is worth noting that as recently as June 2024, the GGL was suggesting the black market accounted for just 4% of the overall sector. The jump to an 18-23% estimate in this latest report represents progress, but the DOCV believes it still dramatically understates the reality.
The Methodology Gap Is the Real Story
The DOCV's criticism of the GGL's survey design deserves serious attention from anyone following the German market. Asking self-selected survey participants whether they have engaged in illegal behaviour is one of the weakest possible methodologies for measuring black market activity. It conflates willingness to self-report with actual behaviour, and it structurally excludes the most active black market users, who are the least likely to volunteer for a regulator-sponsored survey in the first place. The GGL had access to multiple methodologies according to its own 120-page report. That it chose this approach over something like the Nielsen panel data model used by Schnabl raises legitimate questions about whether the regulator is genuinely trying to measure the black market or trying to produce a figure that reflects well on its own performance.
The Stakes of Getting This Wrong
Germany's Interstate Treaty review is arguably the most consequential regulatory moment for the country's licensed online casino sector since the current framework launched in 2021. The restrictions currently in place, particularly mandatory deposit limits and slot spin limits, were designed with player protection in mind, but the unintended consequence has been to make licensed sites structurally less competitive against black market alternatives. If the GGL successfully argues that channelisation is high and the market is healthy, the political will to reform those restrictions will evaporate. Licensed operators will be left competing with one hand tied behind their backs against illegal sites that answer to nobody.
The Schnabl Report Could Change Everything
The updated study expected this summer represents a pivotal moment for the German market debate. If the new Nielsen data supports the DOCV's position that channelisation remains around 50%, it will make the GGL's 77% claim very difficult to sustain publicly. More importantly, it could provide the licensed industry with the evidence base it needs to demand meaningful regulatory reform ahead of the Interstate Treaty conclusion next year. The regulator has moved from claiming 4% black market share in 2024 to acknowledging something in the 18-23% range today. The trajectory is heading in the right direction, but the pace of that reckoning may simply be too slow to save Germany's licensed market from a slow haemorrhage of players to operators who operate without any rules at all.
Sources
Why This Matters
iGaming Times analysis: Germany's GluNeuRStV framework was designed to channel demand into a licensed product set with deliberately conservative product limits (deposit caps, slot stake limits, in-play restrictions). The cumulative effect has been to leave a meaningful share of player demand unmet by the licensed channel; the offshore-share figures consistently estimated by industry sources track higher than the regulator's official projections. Until the product perimeter is widened, channelisation arithmetic continues to support the offshore-channel growth narrative regardless of enforcement intensity.
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