The German Online Casino Association has severely questioned the latest 2025 channelization data released by the Federal Gambling Regulatory Authority, calling it "overly conservative" and flawed in methodology. The GGL report released last week claimed that the channelization rate in Germany reached 77%, with the black market GGR only 547 million euros. However, the vice chairman of DOCV pointed out that the report, based on a survey of 2000 players, has issues of "unrepresentative sample" and "recall bias" — players are unlikely to admit participation in illegal gambling when asked. In plain terms, GGL's data might seriously underestimate the true scale of the black market.
Industry Counterattack: 50% Black Market Share Closer to the Truth
DOCV had commissioned independent research by economists from the University of Leipzig as early as 2023, analyzing Nielsen gambling activity data, which concluded that the black market accounted for as much as 50% of the total. The vice chairman believes this estimate is closer to reality. He pointed out that the GGL report's figure of only 547 million euros for the black market GGR is "overly conservative," as illegal operators offer substantial bonuses, lack player protection, and have no loss limits or spin restrictions, meaning actual betting amounts could be much higher than official estimates. He even revealed that licensed operators have received customer notifications stating they have switched to the black market to avoid the strict restrictions and inspections of the legal market.
The Underlying Dispute in Data: The Struggle Over Regulatory Policy Direction
The core of this data dispute is the upcoming revision of the German "Interstate Gambling Treaty." The industry fears that GGL might use this optimistic report to claim "everything is running smoothly," thus avoiding the need to adjust current policies. Licensed operators are currently facing mandatory deposit limits and slot machine betting limits, and the industry hopes to relax these restrictions in this review. The revision is expected to be completed next year. Meanwhile, economist Günther Schnabl is updating the Nielsen data analysis, with the new study expected to be released this summer, revealing the real market conditions in 2025. Want to keep up with the latest developments in European gambling regulation? PASA official website continues to track.
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