Germany’s black market gambling spend reaches €547m

Germany’s gambling regulator has offered fresh insight into the scale of the country’s black market. A new study commissioned by the Gemeinsame Glücksspielbehörde der Länder (GGL) estimates that unlicensed operators generated €547m in gross gaming revenue (GGR) in 2024. This is a notable increase year-on-year. The findings also suggest that the majority of activity remains within the regulated ecosystem.

Black market growth but strong channelisation

The GGL-backed report places Germany’s black market GGR at €547m for 2024. This is up 17% from €466m in 2023.

Despite the growth, the study estimates channelisation at 77.03%. This shows that more than three-quarters of online gambling activity takes place with licensed operators.

Ronald Benter said the findings reinforce the regulator’s current approach:

“The scientifically calculated channeling rate confirms our previous assumptions about the size of the black market. The results support the fact-based regulatory approach within the framework of the 2021 Interstate Treaty on Gambling.” – Ronald Benter

The figures suggest that while the unlicensed sector is expanding, Germany’s regulated market still dominates overall activity.

How the study measured black market activity

The research was conducted by the Blockchain Research Lab. They used a combination of methodologies to assess the size of the unlicensed market.

A key part was a behavioural survey of 2,000 online gambling users. Lottery players were excluded. Participants identified up to seven platforms they used and reported staking and loss patterns.

Operators were then classified as licensed or unlicensed using GGL data and other sources. Researchers combined this with reported spending to estimate the size of the black market.

The report also reviewed alternative measurement approaches. These included traffic-based estimates, proxy indicators such as tax data and enforcement-led assessments. It concluded that each method carries limitations and showed the need for a combined approach.

Licensed vs unlicensed player behaviour

The survey recorded 4,027 mentions of gambling operators. Of these, 79.7% related to licensed platforms. 20.3% referred to unlicensed sites.

However, unlicensed platforms accounted for a slightly higher share of activity by value. They represented 22.4% of total stakes and 22.97% of player losses.

Players using only unlicensed platforms reported higher monthly spending and losses than those using regulated sites. Average monthly stakes were €1,425 for unlicensed users. Licensed-only players spent €1,243. Losses followed a similar pattern. These were €475 compared to €358.

Session-level data showed smaller differences. Unlicensed users staked €88.96 per session compared to €77.00 for licensed users. The report noted that this gap was not statistically significant.

Licensed brands cited most frequently included Tipico, Bwin, Bet-at-home and Betano. Unlicensed platforms mentioned included Stake.com, WooCasino and PlatinCasino.

Ongoing monitoring and enforcement focus

The study shows the difficulty of precisely measuring illicit gambling markets. It calls for continued monitoring.

Researchers recommend combining repeated player surveys with advanced technical tools. These include machine learning, web crawling and transaction analysis. Blockchain monitoring was also identified as increasingly relevant, particularly for crypto-enabled gambling platforms.

Both the authors and the GGL stressed that the figures should be viewed as indicative rather than definitive. However, they argue that a consistent, multi-method approach will be key to refining future estimates and strengthening enforcement strategies.