Is Germany Underestimating Its Black-Market Problem?

Posted on: February 6, 2026, 07:51h.
Last updated on: February 6, 2026, 07:51h.
- Germany’s regulator pegs online black-market gambling at roughly 25%
- Independent studies suggest illegal play exceeds half of online activity
- Strict rules may be driving high-risk players offshore
The German gaming regulator Gemeinsame Glücksspielbehörde der Länder (GGL) estimates the size of the online black market to be 25% in its 2024 activity report, which means that roughly a quarter of German players play on unregulated sites.

This is a big deal, since in Germany, unlike in many other jurisdictions, the act of merely taking part in illegal gambling is a crime, meaning a significant share of the population could technically be in breach of the law. But according to online gaming and news website Games Hub, the GGL’s estimation is optimistic, and the true figure may be much larger.
High-Stakes Black Market
Some analysts have put the size of the black market at 40% to 60%, Games Hub notes. A late-2025 study by the Handelsblatt Research Institute for sport, Online Gambling in Germany: Channelling and Development of the Black Market, concluded that the black market’s share is likely above 50% — meaning more than half of all online gambling activity happens outside the regulated sector.
The study also suggests that headline participation figures may understate the problem. Researchers argued that high-intensity and high-stakes gamblers are disproportionately active on unlicensed platforms, amplifying the black market’s impact beyond simple player counts.
From the report: “It should be noted in this context that illegal online gambling providers increasingly attract players who play with high intensity and above-average stakes. Therefore, the black market in the gambling sector is even more significant with regard to the volume of gambling than is reflected in the above percentages.”
Germany overhauled its online gaming regulations in 2021, shifting from a patchwork of state-based regulation to a unified framework that is one of the strictest in Europe. The focus was on player protection and minimizing gambling harm.
Reforms included strict limits on stakes (€1 per spin on slots), as well as the speed of play. There were strict limits on marketing and promotions, while OASIS, Germany’s national player self-exclusion database, offers an ever-accessible, 24-hour panic button for players to initiate exclusion immediately.
Changes Ahead
Critics argue, however, that if black-market participation is as widespread as some estimates suggest, these protections may be counter-productive, pushing higher-risk players toward offshore operators where safeguards are weaker or entirely absent.
The GGL is currently undertaking a review of its regulatory framework with the aim of improving channelization — i.e. its ability to draw customers to the regulated market. This could ultimately lead to a softening of regulations as it strikes a more sustainable balance between player protection and market viability.
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