Glücksspiel (GGL), Germany’s Federal Gambling Authority, has warned the Bundesländer (federal states) to treat the threat of illegal online gambling as a serious public health risk.

The warning comes ahead of the GGL’s annual Gambling Addiction Action Day (24 September), with the regulator urging state agencies to scrutinise offers and advertising that promote unlicensed providers.

As Ronald Benter, CEO of the GGL, explained: “Illegal platforms do not offer effective player protection mechanisms. Anyone who plays there runs a significant risk of developing a gambling addiction.”

The Action Day is held under the patronage of Prof. Hendrik Streeck, the Federal Government’s Commissioner for Addiction and Drugs, and this year carries the motto “Gambling Harms – Recognise, Name, Avoid.” 

The 2025 campaign includes a symposium for state authorities to exchange best practices in treating gambling harm, while also reminding consumers to consult the GGL’s whitelist of licensed operators under the Fourth Interstate Gambling Treaty (GlüNeuRStV).

Commissioner rings alarm on Gambling Addiction 

As patron of the campaign, Prof Streeck used the Action Day to provide a stark update on gambling addiction. He noted that 1.3–1.4 million adults are already addicted, with a further 3.5 million at risk.

Around 600,000 minors live with at least one gambling-addicted parent, facing neglect, depression, anxiety, and financial insecurity. Streeck warned that gambling disorder remains one of Germany’s most common addictions, often hidden for years and devastating for families.

Yet headline figures mask a deeper challenge. Experts agree that Germany has significant liabilities in how it measures and interprets gambling harm. There is no academic consensus on how to separate play on licensed versus unlicensed sites, or how to quantify the true social cost.

GlüNeuRStV has no accountability 

Nearly three years since the GlüStV 2021 came into force, the federal regime remains troubled by divisions on data and exposure to black market threats.

The GGL’s Third Annual Activity Report estimated that unlicensed operators accounted for 25% of the online gambling market in 2024. Official figures put total legal stakes at €8.2bn, up slightly from €7.9bn the year before.

For the German Sports Betting Association (DSWV), this represented long-overdue transparency but not accuracy. Chairman Mathias Dahms argued the black market share is far higher, “exceeding 50%” according to studies such as the influential Schnabl report.

One alarming statistic was that the number of illegal German-language sports betting websites jumped 36% from 281 to 382 in a year, against just 34 licensed sites on the GGL whitelist. 

“The ratio of legal to illegal sites is around 1 to 11,” Dahms said. “Illegal providers benefit from offering wider markets, especially in live betting, which is immensely popular. This is precisely why many users switch.”

The dispute reflects a broader question over Germany’s restrictive model. Licensed operators are bound by stringent rules including €1 maximum stakes on online slots, strict deposit caps, narrow bet types and heavy ad restrictions. 

Critics argue that these restrictions make the legal market less appealing. By contrast, illegal sites exploit demand for in-play betting and broader wagering options.

This gap undermines channelisation, the treaty’s core goal of steering players into the regulated market. Critics say that since GlüNeuRStV’s inception, true accountability has been paused, with conflicting statistics fuelling a stalemate between regulator and industry.

GGL hands tied

The GGL, for its part, has pressed ahead with enforcement. Since 2023 it has implemented geo-blocking under the EU Digital Services Act, expanded payment blocking, and lobbied Google to restrict ads to licensed operators. But enforcement is resource-intensive: by late 2024 the GGL was defending 189 lawsuits, many brought by operators challenging licence decisions and restrictions.

The regulator leans heavily on the GlüNeuRStV Atlas compiled by the University of Bremen, but these figures are refuted by the German Online Casino Association (DOCV), which argues they understate the black market and misrepresent consumer behaviour.

Anxieties on Interstate direction 

Underlying these disputes is a constitutional reality: the GGL enforces, but cannot legislate. Any reform — whether on advertising, sponsorship, deposit limits or product scope — requires Bundestag approval, and political opinion remains divided. 

Betting on amateur football has already triggered state-level disputes over integrity and oversight, while also prompting operators like Interwetten to pull wagering markets on amateur sports.

Looking ahead, 2026 is expected to bring a federal law on gambling advertising and sponsorship, likely the next battleground. Until then, both sides invoke player protection: the GGL through uniform restrictions, and the DSWV by demanding a legal market strong enough to outcompete the black market.

As Dahms put it: “With this figure, the GGL is creating more transparency for the market and the public. Fact-based debates are only possible if we have access to reliable official figures—we expressly welcome this step.”

Clarity has not yet delivered consensus. Germany’s online gambling market remains a divided house, with addiction concerns, black market leakage, and regulatory rigidity leaving the future of the Interstate model uncertain.