Germany: Glücksspiel-Survey provides limp actions to fix Interstate gambling regime
The third survey on German gambling prevalence calls for tougher monitoring of gambling environments as the Interstate regime provides stable data, but academics refuse to question unfixed liabilities.
German authorities and the Bundesländer (states) have been urged to strengthen the “Verhältnisprävention” (structural prevention) framework embedded within the Fourth Interstate Treaty on Gambling (GlüStV 2021).
The recommendation forms the principal conclusion of the Glücksspiel-Survey 2025, conducted by the Institute for Interdisciplinary Addiction and Drug Research (ISD) and the University of Bremen. The survey is published on a bi-annual basis, with research funded by Germany’s state lottery association, the Deutscher Lotto-und Totoblock (DLTB).
The third edition of the survey concludes that the Bundesländer and the federal gambling regulator, the Gemeinsame Glücksspielbehörde der Länder (GGL), should prioritise “structural prevention rather than relying primarily on individual responsibility to minimise gambling risks.”
In reviewing current prevention measures, researchers note that German consumers require “environmental safeguards rather than purely educational campaigns” to reduce gambling harms.
On prevalence, the Glücksspiel-Survey was conducted on a nationally representative sample of 12,000 adult respondents (18+), with feedback gathered via telephone and online questionnaires.
Researchers note that the methodology forms part of a continued monitoring programme, following comparable surveys undertaken in 2021 and 2023.
Interstate on stable platform
Gambling participation in Germany has marginally increased to 64.9% (2023: 63.8%), while the share of adults who do not gamble remains stable at roughly 35%. A breakdown shows lottery products as the most common activity, played by 40% of respondents, followed by scratch cards (35%) and retail sports betting (17%).
Land-based activities continue to dominate over online play. While the survey indicates that online gambling participation (sports betting and casino) has increased to around 11–12% in 2025, Germany continues to lag behind most European markets in terms of online gambling engagement.
Problem gambling prevalence is assessed as broadly stable. The survey estimates that 0.9% of adults meet the criteria for pathological gambling, equating to approximately 630,000 individuals nationwide.
A further 2.5% are classified as problem gamblers, while 1.9% are considered at risk. Overall, the study concludes that around 5% of German adults display some level of gambling-related risk behaviour, corresponding to an estimated 3.4 million people.
Despite relatively stable prevalence figures, the survey places emphasis on public attitudes towards safeguards. Researchers report that 78% of respondents support restrictions on gambling advertising.
However, the study provides no detailed breakdown of the types of restrictions supported, such as sponsorship bans, watershed limits or comprehensive advertising prohibitions.
Respondents also expressed strong support for centralised protection measures. The survey found that 82% of participants backed the nationwide OASIS self-exclusion register, while 85% supported enhanced staff training for behavioural intervention in gambling venues and online platforms.
Returning to the risks associated with gambling formats, the study concludes that online gambling products carry a higher correlation with disorder than land-based activities. In particular, the research highlights online casino games and slot products as higher-risk formats.
The report states: “Forms of gambling characterised by high event frequency and rapid play sequences – particularly online casino slots and virtual slot machines – show a significantly stronger association with problematic gambling behaviour. Preventive measures should therefore focus especially on these higher-risk products.”
Of note, the survey does not provide public sentiment regarding several of the most debated product restrictions introduced under the Interstate Treaty, including the €1,000 monthly cross-operator deposit limit, the €1 maximum stake on online slots, and the mandatory five-second spin interval without multi-play functionality.
Researchers emphasise that the Glücksspiel-Survey should not be interpreted as a direct critique of the GlüStV 2021 framework, as the analysis focuses primarily on public perception of gambling risks and protective measures introduced since the market opened in 2021.
“The Glücksspiel-Survey is a population-based study designed to measure gambling participation, gambling-related problems and attitudes toward prevention measures. It does not constitute an evaluation of the regulatory framework itself.”
Notably, the study also offers no conclusions regarding the scale of black-market gambling activity or the channelisation of players toward the regulated market, issues that have become increasingly contested since the implementation of the interstate regime.
Nein to Glücksspiel survey
Responding to the findings, the German Online Casino Association (DOCV) and the German Sports Betting Association (DSWV) issued a joint statement through their respective presidents, Dirk Quermann and Mathias Dahms:
“Every person with a gambling disorder is one too many. In the regulated market, state-approved protective measures are in place – from deposit limits and the nationwide OASIS exclusion system to mandatory warnings and breaks from gambling. None of these exist in the black market.
“Anyone who takes player protection seriously must therefore also take the growing black market seriously: there, vulnerable players are unprotected.”
As such the trade bodies reject the “context of the current study presentation” – as its monitoring and continue to hold “significant methodological flaws” that are not reflective of the current state of play of the Interstate regime.
DOCV and DSWV will continue to interpret the impacts of online gambling such as “long-term studies by the Federal Centre for Health Education (BZgA) and a Forsa study in 2024 identified approximately 200,000 people with problematic gambling behavior (0.37 percent of the population over 18).”
No consensus or common fixes
Despite objections from industry stakeholders, the Glücksspiel-Survey 2025 carries particular significance in 2026 as attention turns to the Gemeinsame Glücksspielbehörde der Länder (GGL), which is mandated to deliver its five-year evaluation of the Interstate Treaty on Gambling to the Bundestag.
The GGL maintains that its review will assess whether the GlüStV 2021 framework has successfully balanced player protection, market viability, advertising controls and the enforcement of online gambling laws and standards.
However, optimism remains limited that the GGL, state authorities or the Bundestag will recommend a substantive overhaul of the interstate regime and its restrictions.
German gambling continues to be marked by what many observers describe as the highest exposure to black-market activity among Western European jurisdictions.
Estimates frequently cited by industry groups, media analysts and government advisers suggest that between 40% and 50% of online gambling revenues may be flowing to unlicensed operators, highlighting a structural weakness in the current framework.
Absent of political consensus for reform, growing liabilities are likely to remain a ‘structural feature’ of an unfixed Interstate regime.
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