The online casino sector in Germany has cautioned the incoming Chairman of the Glücksspielbehörde (GGL) not to ignore the recommendations of his predecessor and concentrate on bettering channelization and fighting the black market without any incursion on regulated licences.
The demand comes from the trade group Deutscher Online Casinoverband (DOCV) after the joint gambling authority of the federal states (GGL) moved to the presidency of Christian Hochgrebe.
As the country begins a crucial phase of its gaming framework, the GGL’s Administrative Board handed over the baton of its yearly presidency to the City-State of Berlin in July and appointed Hochgrebe to lead the regulator’s cooperation with Germany’s 16 Länder.
New German gambling leadership
Hochgrebe takes office as the GGL is preparing the first statutory review of the Fourth Interstate Treaty on Gambling (GlüStV 2021).
“The [regulator] is well prepared” for the next phase of the development of the treaty, with goals geared toward improving oversight of licensed operators and stepping up the fight against illegal gaming structures, he said.
His predecessor Sandro Kirchner used the occasion of the publishing of the GGL Activity Report 2025 to admit that the black market in Germany "cannot be completely eradicated" and recognized that "illegal services must be made more expensive and less attractive through enforcement measures".
The DOCV said it understood Kirchner's call for communication but warned the GGL should not perceive compromise as relaxing enforcement against unlawful operators.
The trade association blamed the increasing regulatory restrictions since the introduction of the GlüStV regime, saying such measures have made Germany's legal market less appealing and increased the appeal of unlicensed providers.
“The GGL has to continue the fight against the illegal market,” stated Julia Lensing, Managing Director of the DOCV.
“Progress will be made by a vibrant legal market and regular enforcement against illegal providers. “Licensed operators provide youth protection, deposit limits and algorithm-based player monitoring, illegal providers do not and there is no tax revenue.”
The group again called for stricter website blocking, payment blocking, geoblocking and closer coordination with search engines to restrict the advertising of unlawful gambling services, and expressed readiness to engage with regulators, policy makers and researchers to improve channelization.
It has also revived calls for a modernization of Germany’s criminal code to better prosecute cross-border online gambling offenses.
Controls to Soften
The discussion comes as Germany has began to carefully soften one of the most criticized parts of the Interstate Treaty.
From 1 July, regulated internet casinos have been allowed to offer higher maximum stakes under tight rules. Players 21 and over can make a maximum bet of €3 each spin, while the €5 maximum stake is reserved for those who have completed a necessary 90-day assessment period without any signs of dangerous gambling behavior.
The DOCV praised the reform as a slight improvement, but argued that many of the market’s most restrictive regulations remain unaltered.
Such measures include the national €1,000 per month cross-operator deposit limit, enforced through the LUGAS monitoring system, as well as extensive product limits that continue to set Germany’s regulated market apart from many European states.
While the Interstate Treaty is subject to a statutory review, it is expected that advertising rules, deposit limitations and broader consumer protection measures would be scrutinized. It is unclear however whether the Länder would again look at further product limits that business argues continue to make the regulated market less competitive.
The efficiency of Germany’s gambling regime is fiercely questioned. The GGL estimates 77% of online gambling activity is directed into the regulated sector, totaling some €1.8bn in gross gaming revenue. It estimates the illegal market earned €546.9m in GGR.
The DOCV and other industry stakeholders dispute those numbers, claiming that channelization has deteriorated dramatically and may now have fallen below 50% as consumers move to unlicensed offshore operators with fewer restrictions and a wider choice of products.
With Hochgrebe now heading both the treaty review and the GGL’s strategy, the next phase of Germany’s gambling regulation will probably depend on whether policymakers can step up enforcement against illegal operators and make the licensed market more competitive.
