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A Frankfurt investigation involving €5.86 billion in wagers has led the German Sports Betting Association to question whether current estimates capture the real size of unlicensed online gambling in Germany.
The DSWV says the figure, covering only July 2021 through the end of 2023 and one criminal investigation, deserves comparison with the latest official estimate that places the unlicensed online market at roughly 23%.
Good to Know
- Frankfurt prosecutors linked about €5.86 billion in stakes to unlicensed gambling platforms over two and a half years.
- The figure represents wagers placed, not operator revenue.
- GGL research estimates 77.03% of German online gambling activity reaches licensed operators, leaving 22.97% outside the regulated market.
DSWV Questions Germany Black Market Measurement
DSWV President Mathias Dahms said one investigation reaching almost €6 billion should trigger another look at previous assumptions.
“Nearly six billion euros in wagers over two and a half years in a single investigation must prompt a critical review of previous assumptions about the size of the black market. If even a single case reveals such proportions, it inevitably raises the question of whether previous black market estimates realistically reflect the actual scope of the illegal market.”
The association did not provide its own estimate. Instead, it called for stronger data collection and consistent enforcement against operators without German licences.
A comparison with the regulated sports betting sector gives the Frankfurt number added context. Licensed German sports betting operators recorded €8.3 billion in stakes during all of 2025, according to DSWV data. The €5.86 billion identified by prosecutors therefore equals more than 70% of one full year of regulated sports betting turnover, although the figures cover different products and periods and should not be treated as directly equivalent.
GGL Puts Channelisation at 77 Percent
Germany gambling regulator GGL did not publish a separate 2025 black market estimate in its latest activity report. Instead, it relied on research covering 2024.
The study by Blockchain Research Lab calculated the unlicensed share of online gambling at 22.97%, giving Germany a legal market channelisation rate of 77.03%. GGL said the methodology supported earlier assumptions about the size of the unlicensed sector.
DSWV now argues that the Frankfurt case gives regulators another data point to consider.
Player protection sits behind the dispute as well. Operators without a German licence do not follow the same requirements covering deposit limits, identity checks and player exclusion systems.
“Player protection only works where the rules apply and are enforced,” Dahms said.
Germany is already reviewing its regulatory framework under the scheduled evaluation of the 2021 State Treaty on Gambling. GGL says improved market measurement and stronger data quality will form part of its regulatory work ahead of the next licensing cycle from 2027.
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