• Germany’s new federal gambling regulator, the GGL, has released its first-ever quarterly market analysis for the newly regulated online market.
• The data for H1 2025 shows mixed results, with stakes on virtual slots rising slightly to €1.12 billion in Q2, while online poker stakes fell to €184 million.
• The report comes as the industry continues to grapple with the strict rules of the 2021 State Treaty (GlüStV), including a €1 slot stake limit and a 5% turnover tax.
• The GGL continues to wage a major battle against the black market, which it officially estimates at 25% of the total market, though some industry reports suggest the figure is closer to 50%.
• The regulator has called for more impactful measures to combat illegal operators, citing issues like “cloaking” that allow sites to evade detection by search engines.

Germany’s new national gambling regulator, the Gemeinsame Glücksspielbehörde der Länder (GGL), has published its first-ever quarterly market report, providing a transparent, if mixed, first look at the performance of the country’s legal online market.

The data for the first half of 2025 shows that stakes on licensed virtual slots grew slightly from just under €1.1 billion in Q1 to €1.12 billion in Q2. In contrast, stakes on online poker saw a decline over the same period, falling from €204 million to €184 million. The total value of stakes across all monitored verticals, which also includes sports and horse racing betting, decreased from €3.5 billion in Q1 to €3.2 billion in Q2. The GGL stated it will publish these reports quarterly to “ensure greater transparency in the legal gambling market.”

Operating Under a Strict Regime

These results must be viewed in the context of Germany’s highly restrictive regulatory framework. The 2021 State Treaty on Gaming (GlüStV), which established the new licensing regime, also introduced some of the toughest operating conditions in Europe. These include:

• A cross-operator monthly deposit limit of €1,000 per player.
• A maximum stake limit of €1 on all online slot spins.
• A controversial 5% tax levied on all stakes, not on gross gaming revenue.

Critics have long warned that these stringent measures make the legal market uncompetitive and risk funnelling a significant portion of players towards the unregulated black market.

The Battle Against the Black Market

The GGL’s own data and enforcement reports highlight the scale of this challenge. The regulator itself is engaged in a major, ongoing battle against unlicensed operators. While the GGL officially estimates that the black market accounts for 25% of Germany’s total gaming activity, other independent reports have suggested the figure could be as high as 50%.

The regulator’s 2024 Activity Report noted that it had identified 858 German-language illegal sites. It has since taken significant action, confirming the removal of 231 illegal sites and the prohibition of a further 657 through automated geo-blocking initiatives.

A Call for More Powerful Tools

Despite these efforts, the GGL has acknowledged that it needs more impactful measures to win the fight. CEO Richard Benter has previously called for a more unified European approach and has highlighted the technical challenges posed by illegal operators, such as the use of “cloaking.” This technique allows sites to present different content to search engines like Google than they do to users, making them incredibly difficult to detect and block.

The situation leaves the GGL in a difficult position: it is tasked with overseeing a legal market constrained by a treaty that many believe is uncompetitive, while simultaneously fighting a vast and sophisticated black market that thrives on those very constraints.