DOCV Questions GGL’s German Black Market Data

Germany’s online casino association Deutscher Online Casinoverband (DOCV) expressed disagreement with the Gemeinsame Glücksspielbehörde der Länder (GGL) recent update on the country’s regulated market. According to the former body, the regulator underestimated the black market.

In an interview with iGamingBusiness, DOCV vice president and Entain regulator affairs council Simon Priglinger-Simader said that the GGL’s estimation of the prevalence of illegal gambling is too rosy. According to the regulator, the black market occupies a measly 4% market share.

However, the DOCV pointed out that the GGL report said that the black market was worth EUR 600 million, compared to the legal market’s EUR 3 billion. This would mean that illegal operators’ market share is closer to 20%, which, Priglinger-Simader said, is not ideal.

For comparison, a 2023 study commissioned by the DOCV and Deutscher Sportwettenverband (DSWV) and authored by Dr Gunter Schnabl, suggested that only 50.7% of the players were gambling within the regulated online sector. Conversely, 49.3% used unlicensed EU providers or illegal offshore websites, the study suggested.

GGL Will Update Its Figures

Other industry stakeholders also noted this discrepancy and dismissed GGL’s report. While the GGL is set to publish updated estimates soon, its unrealistic figures definitely didn’t please the regulated sector.

Priglinger-Simader told iGB that the industry is really looking forward to hearing the GGL’s updated estimates for the size of the black market, saying that it would be an “important and interesting step forward.”

Unfortunately, the final GGL evaluations will likely face delays. Originally set to be published in 2026, the report’s release date will likely be postponed, considering that June’s update itself was six months late, the DOCV noted.

The association therefore expects the final report to come in 2027 at the earliest. According to Priglinger-Simader, the regulator should find some way to implement some anti-black market measures earlier, lest it allows illegal operators to “thrive without having any consequences.”  

Priglinger-Simader concluded that he acknowledges the difficulties faced by the GGL and the fact that it has been doing its best to regulate the market. He suggested that lower tax rates and less restrictive regulations could possibly make the legal market more competitive. Despite that, Priglinger-Simader was optimistic about the gradual growth of the legal market.