GGL Takes Stock: Effective Supervision Achieved, Agile Regulation Needed

Enforcement Against Illegal Gambling Made Effective

Around 100 employees now supervise a largely established legal online gambling market, monitor compliance with player protection regulations, and successfully take action against illegal offers.

At the same time, the GGL sees regulation facing new challenges. Business models, technical structures, and forms of illegal gambling are developing faster than a state treaty legal framework can be amended. The authority therefore advocates using the evaluation of the 2021 State Treaty on Gambling to make regulation more adaptable and to strengthen the GGL's professional leeway for action within the legal framework.

Authority Desires New Approaches for Regulation to Keep Pace with Market Development

"Five years ago, there was a political mandate. Today, there is a functional, nationwide specialist authority," says GGL Board Member Ronald Benter. "We had to recruit personnel, build structures and expertise, and simultaneously shape a completely new supervisory area in practice. Today, we have the experience, the specialist knowledge, and the technical capabilities to effectively supervise a highly digitized and internationally characterized online gambling market. This is the starting point for the next stage of development."

A Nationwide Uniformly Supervised Market

The GGL was created in response to the changing conditions of the gambling market. Online gambling knows no national borders, operators act internationally, and technical business models develop at high speed. With the 2021 State Treaty on Gambling, the 16 federal states pooled essential areas of their respective gambling supervision into a joint authority. The goal was to enable uniform regulation of the online gambling market and effective enforcement.

Legal Market Under Uniform Supervision 

A central success of the past five years is the establishment of a legal online gambling market that is uniformly supervised nationwide.

Currently, 129 operators and intermediaries hold a permit from the GGL and are listed on the official whitelist. A total of 229 gambling websites are permitted.

In 2025, the authority carried out more than 600 supervisory procedures on permitted operators to check whether they were complying with legal requirements for player protection, advertising, and the specific design of gambling offers. Technical and organizational changes by operators are also monitored. In the event of violations, the GGL has various supervisory instruments at its disposal. For serious or repeated violations, measures such as public warnings or the revocation of permits are used. The GGL has revoked two permits so far.

The goal of the GGL's supervisory activities is not solely to control individual operators or offers. Rather, it is about recognizing developments early on, assessing risks, and permanently ensuring compliance with legal requirements. This also includes continuously reviewing these requirements for their accuracy.

Enforcement Against Illegal Gambling Significantly Expanded 

Parallel to supervising the legal market, the GGL has continuously expanded its enforcement against illegal gambling over the years.

This development is particularly evident in prohibition proceedings: their number rose from 68 in 2022 to 287 in 2025, thus more than quadrupling.

In total, the GGL checked approx. 6,300 websites for illegal gambling offers or related advertising by the end of 2025. In doing so, the authority is increasingly relying on a holistic enforcement approach. It not only takes action against individual operators but also systematically addresses their surrounding environment. As a result, alongside payment service providers, advertising partners, affiliate networks, and hosting providers, other service providers related to the technical infrastructure are increasingly being included in supervisory measures.

"We do not measure the success of our work solely by how many proceedings we conduct or how many official notices we issue," Benter emphasizes. "What matters is the impact. With our measures, we disrupt the functionality of illegal business models and make their operation more expensive in the long term."

The impact of this enforcement can be seen, for example, in the access options to the German market: 1,843 illegal websites were no longer accessible from Germany in 2025 due to prohibitions or network blocks. Furthermore, measures taken against payment service providers cut off 178 websites from access to established payment channels.

254 illegal operators had discontinued their offerings for the German market by the end of the year.

The visibility of illegal operators was also reduced, as the GGL successfully expanded its enforcement to large digital platforms like Google. Since September 2024, only permitted gambling operators have been allowed to advertise via Google Ads in Germany.

Gambling Supervision Becomes Increasingly Data-Driven 

Over the past five years, the GGL has simultaneously created the technical and organizational prerequisites for increasingly data- and technology-supported supervision.

With the cross-state gambling supervision system LUGAS, it has a central technical infrastructure for essential areas of player protection and market surveillance. At the end of 2025, 5.3 million registered players were recorded in the central files. Through the evaluation of valid safe-server data, the supervisory authority has an increasingly broad data foundation at its disposal.

"We supervise a market whose business models and technical structures sometimes change faster than classic administrative processes," says Benter. "Therefore, we must not only apply the law. We must understand the market technically. Today, good regulation requires legal expertise, data competence, and technical understanding in equal measure."

77 Percent of the Online Market Regulated, Black Market Remains a Challenge 

Looking at channelization, the GGL also draws a positive, yet differentiated conclusion.

According to the latest scientific channelization study, regulated offerings account for around 77 percent of the online gambling market. This means the vast majority of online gambling now takes place within the permitted market.

At the same time, this rate also means that a not inconsiderable part of the market remains outside of regulation. Pushing back illegal offers further therefore remains a central task for the GGL.

A Joint Specialist Authority of the 16 Federal States

The GGL stands for a special form of federal cooperation. The 16 federal states decided to no longer view an increasingly digital and international market solely from individual state perspectives, but rather to pool parts of their respective gambling supervision in the GGL.

Within a few years, a joint administrative practice has thus emerged across state borders.

"The establishment of the GGL was also an ambitious step organizationally: 16 federal states pooling essential parts of their gambling supervision into a joint authority," says Benter. "After five years we can say: This model works. Central pooling of specialist knowledge creates considerable added value, especially in a digital and internationally characterized market. Bringing different perspectives together and preparing decisions jointly is a demanding process."

The Next Stage of Development: Regulation Must Keep Pace with the Market - More Professional Leeway for Dynamic Supervision 

Alongside this positive outcome, the GGL also associates expectations for the next stage of development.

The 2021 State Treaty on Gambling is currently being evaluated. From the GGL's perspective, this process should not only review the effectiveness of existing regulations. It is also about how regulation can react to a market whose business models and technical structures sometimes change within a few months.

The experiences of the past five years show an area of tension: While new business models, technical developments, or forms of illegal gambling can emerge quickly, changes to the State Treaty's legal framework regularly require a multi-year political and legislative process.

"A market that changes rapidly in technological and economic terms needs a supervisory authority that can react promptly to new developments," explains Benter. "We should therefore use the evaluation not only to review existing regulations but also to answer the question of how our regulatory system can become faster and more adaptable."

The GGL therefore advocates for being able to use its grown professional expertise even more directly for effective and contemporary supervision in the future.

It wants to pursue this path together with the Administrative Board. The Administrative Board represents both the interests of the federal states and the professional advancement of the GGL. The goal should be to bring state interests and professional expertise together even better and to give the GGL the necessary professional leeway for action where a quick reaction to new market developments is required.

This leeway can help adapt supervision more quickly to new developments, reduce administrative effort, and simultaneously relieve the federal states.

For the next five years, the GGL therefore formulates a clear ambition: Regulation must be able to keep pace with the development of the market. The goal remains effective, evidence-based gambling supervision that guarantees player protection in the legal online gambling market and consistently pushes back illegal offers.