DOCV director disputes GGL estimate of Germany’s illegal online gambling market
Regulation2 min read
DOCV director Julia Lensing disputed the GGL’s estimate that illegal online gambling accounted for 22.97% of Germany’s market in 2024. Lensing cited an unpublished research update that she said put illegal operators’ share of online playing time at 57% in 2025; the findings could not be independently checked. She also called for changes to gambling rules and more market data from the GGL.
The GGL estimated the share of the illegal online gambling market in Germany for 2024 at 22.97%. Lensing, director of DOCV, said that this percentage does not give a good picture of the size of the illegal market. She referred to several studies in an interview.
According to calculations by the research firm H2 Gambling Capital, 64% of German players would use illegal providers, Lensing said. She also pointed to research by Professor Gunther Schnabl of the University of Leipzig. In her account, an earlier study from 2023 showed that more than half of online playing time took place with illegal providers. An unpublished update of that research would show that this share rose to 57% in 2025. The research update has not been made public and could not be independently checked.
Lensing argues that the GGL underestimates the illegal market because the regulator puts too much emphasis on the number of visits to illegal gambling websites. In her view, access data say too little about consumers' actual playing behaviour. She calls for time spent on gambling sites and the advertising activity of illegal providers to be included when determining the size of the market.
The size of the German illegal gambling market has been under discussion for some time. The director of licence holder Rootz previously said that, in his view, 80% of play on online slots took place with illegal providers. DOCV had also called for the rules to be eased at that time.
Lensing says the 5.3% tax on stakes on virtual slots, advertising restrictions and complicated licensing procedures make the legal offer less attractive. She said a DIW Econ calculation would show the effective tax burden rising to between 45% and 60% of gross gaming result. The DOCV director wants a tax on net stakes, a nationwide licensing system and fewer administrative barriers. She also asks the GGL to publish more market data.
The GGL published its activity report for 2025 in July 2026. In the report, the regulator addressed, among other things, the size of the legal market and its approach to illegal providers.