The licensed gambling operators in Germany, as regulated by the Gemeinsame Glücksspielbehörde der Länder (GGL), are listed on the GGL’s official whitelist, which is regularly updated to reflect operators authorized to offer online sports betting, virtual slot machines, and online poker under the 2021 Interstate Treaty on Gambling (GlüStV).
Licensed gambling operators in Germany, regulated by the Gemeinsame Glücksspielbehörde der Länder (GGL), are exerting pressure on the German government to address illegal offshore betting sites through a combination of advocacy, industry lobbying, legal arguments, and highlighting the economic and social harms of the black market.
The DOCV and DSWV, representing major licensed operators like Tipico, Entain, and bet365, have been vocal about the black market’s impact.
The DOCV has publicly criticized the GGL’s estimate of a 4% black market share (€400-600 million) as underrepresenting the issue, suggesting a 20% share of the online gambling market.
For instance, DSWV’s warnings about illegal operators during UEFA Euro 2024 highlighted how unlicensed sites exploit major events, urging the government to act swiftly. These campaigns amplify pressure by framing offshore sites as a societal issue requiring urgent policy responses.
Both associations advocate for regulatory reforms to make the legal market more competitive, such as reducing the 5.3% stake tax or loosening restrictions on game types (e.g., allowing live casino games).
DSWV President Mathias Dahms has emphasized the need for a “level playing field” and stricter enforcement against illegal operators, citing the black market’s €4 billion revenue (54% of online gambling, per Yield Sec 2024). Such statements are directed at policymakers, urging federal and state governments to prioritize enforcement to safeguard licensed operators’ market share.
Licensed operators, such as Gauselmann Group (Merkur) with its extensive land-based and online presence, argue that their investments in Germany – creating jobs and infrastructure – are undermined by unlicensed competitors.
Licensed operators’ pressure on the German government is driven by self-interest – protecting market share and profitability – but it aligns with broader public goals like consumer protection and tax revenue. However, their advocacy often glosses over how Germany’s restrictive regulations (5.3% tax, €1,000 deposit cap, game bans) fuel the black market’s appeal.
By focusing on banning offshore sites, operators may deflect attention from needed reforms, such as lowering taxes or expanding legal game offerings, which could reduce demand for unlicensed platforms.
Additionally, their calls for international cooperation, while valid, face practical hurdles due to Curaçao’s autonomy and Germany’s limited diplomatic leverage.
The government’s 2025 coalition agreement to “improve the fight against illegal gambling” suggests some responsiveness, but progress remains slow, reflecting the complexity of balancing enforcement with market competitiveness.
Licensed operators in Germany, such as Tipico, Entain, Gauselmann, and bet365, pressure the government to ban illegal offshore betting sites through:
- Lobbying via DOCV and DSWV, citing studies like the 2023 Leipzig report to demand stricter enforcement.
- Highlighting tax revenue losses and economic impacts of the €4 billion black market.
- Emphasizing consumer risks like fraud and problem gambling on unlicensed sites.
- Public campaigns and supporting legal actions to raise awareness.
- Advocating for international cooperation, particularly targeting Curaçao-based operators.
Leveraging their high compliance costs to argue for a level playing field.
Their efforts focus on stronger enforcement (e.g., IP blocks, payment restrictions) and regulatory reforms to protect their market share, but success hinges on addressing the legal market’s uncompetitive structure, which drives players to offshore sites.
As of the latest available data, primarily from 2023 and early 2024, the GGL has issued licenses to a limited number of operators, with specific companies highlighted across various sources.
Online Slots (Virtual Slot Machines)
Number of Licenses: Approximately 27 providers as of February 2023, with 39 operators licensed by late 2024.
Notable Operators:
- Gauselmann Group (Merkur): A subsidiary received the first German license for online slots in May 2022. Operates platforms like Merkur-Spiel.de.
- Entain plc: Licensed for platforms such as bwin.de and ladbrokes.de.
- bet-at-home.de: A well-known platform with a German license for online slots.
- stargames.de: Operated by Greentube, licensed for virtual slots.
- winfest.de: Licensed for online slots, popular among German players.
- wunderino.de: A prominent online casino platform with a German license.
- leovegas.de: Operated by LeoVegas, licensed for virtual slots.
- Other Operators: Additional platforms like Löwen Play, Jokerstar, BingBong, JackpotPiraten, and SlotMagie are mentioned in industry reports and on platforms like GambleJoe, reflecting a growing number of licensed slot providers.
Online Poker
Number of Licenses: 5 providers as of November 2022, with no significant increase reported by 2024.
Notable Operators:
- Entain plc: Received the first German license for online poker in November 2022, operating platforms like bwin.de.
- Other Operators: Specific names for the remaining four poker licenses are not detailed in the sources, but they are likely among the operators also licensed for slots or sports betting, given the overlap in licensing.
Sports Betting
Number of Licenses: 30 licenses issued as of 2023.
Notable Operators:
- Tipico: A major player with over 1,300 franchises in Germany and Austria, licensed for online sports betting since 2020. Operates tipico.de.
- bet365: Licensed for sports betting, a prominent international operator in Germany.
- Bet-at-home: Licensed for sports betting alongside its slots operations.
- Bwin: Operated by Entain, licensed for sports betting.
- Interwetten: A licensed sports betting provider active in Germany.
- LeoVegas: Licensed for sports betting in addition to slots.
- Other Operators: Additional sports betting providers include platforms like HappyBet and Betano, which are mentioned in industry discussions but not always explicitly tied to the whitelist in the provided sources.
Online Casino Table Games (Schleswig-Holstein)
Number of Licenses: 4 operators licensed as of September 18, 2024.
Licensed Operators:
- Tipico: Awarded a license to operate online casino table games (e.g., roulette, blackjack) in Schleswig-Holstein.
- BluBet: Licensed for online casino games in Schleswig-Holstein.
- Cashpoint: An Austrian operator licensed for table games in Schleswig-Holstein.
- Skill on Net: Licensed for online casino games in Schleswig-Holstein. It is the first state to grant licenses for online table games to private operators, with North Rhine-Westphalia planning a tender process for mid-2025. Other states like Bavaria, Saxony, and Thuringia maintain state monopolies for table games, limiting private operator access.
How big is Germany’s gambling black market?
Estimates of Germany’s gambling black market vary widely depending on the source.
The German gambling regulator, Gemeinsame Glücksspielbehörde der Länder (GGL), reported in its 2023 annual report that the black market accounted for about 4% of the total gambling market, generating between €400 million and €600 million in gross gambling revenue (GGR).
This compares to the legal market’s €13.7 billion GGR, of which €3 billion came from online gambling.
What are the main operators in it?
Identifying the main operators in Germany’s gambling black market is challenging due to the clandestine nature of these activities and the lack of comprehensive public data. The German gambling regulator, Gemeinsame Glücksspielbehörde der Länder (GGL), and industry reports provide some insights but do not typically name specific operators, focusing instead on aggregate trends and enforcement actions. However, available information offers clues about the types and origins of these operators.
In 2023, the GGL identified 207 unlicensed operators offering gambling services through 843 German-language websites. Of these, over 60% (approximately 132 operators) were based in Curaçao, a common jurisdiction for offshore gambling sites due to its lenient regulations.
Additionally, 37 operators were located within the EU, while 147 were based outside, with 23 untraceable to any specific country. These operators primarily offer online casino games, virtual slots, sports betting, and illegal secondary lotteries, targeting German players with accessible, German-language platforms that evade local regulations.
Industry reports, such as a 2023 study by the University of Leipzig commissioned by the German Online Casino Association (DOCV) and German Sports Betting Association (DSWV), indicate that nearly half of online gambling in Germany occurs with unlicensed operators. These entities thrive due to less restrictive offerings compared to the legal market, which is constrained by high taxes (5.3% stake tax), deposit limits (€1,000 monthly cap), and game restrictions (e.g., €1 per spin limit for slots).
Black market operators often provide live casino games, progressive jackpots, and live betting, which are prohibited under Germany’s 2021 Interstate Treaty on Gambling.
Yield Sec, an intelligence platform tracking illegal gambling, reported that in 2024, 1,926 unlicensed operators targeted the German market, up from 1,620 in 2023. These operators interacted with 15.8 million Germans, generating an estimated €4 billion in gross gaming revenue (GGR), or 54% of the total online gambling market.
Their success is attributed to offering 9.2 times more products than legal operators, bypassing know-your-customer (KYC) requirements, and avoiding player protection measures like self-exclusion schemes.
How much of a role does Curaçao play in this proliferation
Curaçao plays a significant role in the proliferation of Germany’s gambling black market due to its lenient regulatory environment and status as a hub for offshore online gambling operators.
Curaçao’s appeal stems from its low-cost licensing, minimal oversight, and lack of stringent compliance requirements compared to EU jurisdictions like Germany, where the 2021 Interstate Treaty on Gambling imposes high taxes (5.3% stake tax), deposit limits (€1,000 monthly cap), and restrictions on game types (e.g., no live casino or progressive jackpots).
Operators licensed in Curaçao can offer a broader range of products, including live betting and virtual slots without spin limits, which are prohibited in Germany’s legal market. This flexibility allows Curaçao-based operators to attract German players seeking less restricted gambling experiences.
Is the German government in touch with Curaçao to stop the illegal gambling sites from operating in the country?
The German gambling regulator, Gemeinsame Glücksspielbehörde der Länder (GGL), has actively targeted unlicensed operators, many of which are based in Curaçao.
Curaçao has been criticized for its lax oversight, enabling illegal gambling operators to target regulated markets like Germany.
A 2025 investigation by Follow the Money highlighted Curaçao’s role in facilitating illegal gambling networks, with shell companies like Bellona NV operating unregistered sites targeting German players.
European regulators, including Germany’s, have issued warnings and fines, but these often go unanswered due to Curaçao’s limited enforcement.
The Netherlands has played a role in pushing Curaçao to reform its gambling regulations.
In 2021, Dutch Minister for Legal Protection Sander Dekker announced an action plan to address illegal gambling from Curaçao, following reports that 40% of global unregulated gaming ran through the island.
Negative Roles of Cryptocurrency in Germany’s Gambling Black Market
Many offshore gambling sites, especially those based in jurisdictions like Curaçao, accept cryptocurrencies such as Bitcoin, Ethereum, or stablecoins like USDT. These platforms often require minimal or no know-your-customer (KYC) verification, allowing players to gamble anonymously. This undermines Germany’s mandatory OASIS player-blocking system and other protective measures designed to prevent problem gambling and money laundering.
Unlike regulated platforms, unlicensed crypto gambling sites often lack mechanisms for resolving disputes or refunding players in cases of fraud or technical issues. Since crypto transactions are irreversible, players risk losing funds to scams or insolvent operators.
Cryptocurrency’s pseudonymous nature makes it attractive for money laundering through gambling sites. Unlicensed operators can use crypto to obscure the origins of illicit funds, a concern raised by European regulators.
Crypto’s role is driven by user demand for privacy, speed, and flexibility, which the legal German market fails to meet due to restrictive regulations (e.g., high taxes, limited payment options). Players may view crypto as a positive feature, enabling access to a broader range of gambling products unavailable in the regulated market.
Cryptocurrency’s role in gambling reflects its growing acceptance globally, not a phenomenon unique to Germany.
Players may use crypto for convenience or ideological reasons (e.g., distrust of centralized banking), and offshore operators capitalize on this trend. Blaming crypto alone overlooks the structural issues in Germany’s gambling regulations that drive players to the black market.