Germany's GGL (Joint Gambling Authority of the Länder) published its 2025 activity report on 3 July 2025, offering the most detailed picture yet of how the country's unified gambling authority is maturing from a licence-issuing body into a fully operational supervisory regulator. The headline finding: enforcement and supervision measures are producing measurable results.
Supervision Takes Centre Stage
Having prioritised licence issuance in its early years, the GGL shifted its operational focus in 2025 decisively toward structured oversight of authorised operators. The primary instruments included supervisory dialogues, both event-driven and routine monitoring measures, and intelligence gathered through market observation. Internal coordination between specialist departments was further strengthened, contributing to a more consistent supervisory practice across the regulated sector.
Technical Infrastructure and Safe-Server Compliance
GGL's Supervisory Mandate Under the 2021 State Treaty on Gambling
The GGL was established on 1 January 2023 as Germany's first centralised gambling regulator, replacing a fragmented 16-state licensing system. Its founding legal basis — the 2021 State Treaty on Gambling — grants it authority over online casino, poker, virtual slot, and sports betting licences simultaneously, a scope no previous German body held. The 2025 shift toward active supervision was structurally anticipated in the treaty: the GGL was always designed to evolve from a licensing authority into a continuous compliance monitor once the initial licence portfolio was populated.
The GGL continued building out its technical infrastructure in 2025, with the stated goal of establishing a reliable, comparable data foundation for supervision, analysis, and future regulatory decisions. Enforcing mandatory and correct use of Safe Servers by licensed operators remained a demanding process — but one the authority views as essential groundwork for improving data quality across the board.
Targeting the Full Illegal Gambling Ecosystem
Enforcement against unlicensed gambling in 2025 moved beyond targeting operators in isolation. Service providers facilitating illegal offerings came increasingly into focus — a deliberate shift toward addressing the market and process context in which illegal activity operates, rather than individual sites alone. The GGL also worked closely with platform operators to reduce the visibility of illegal content in the digital space. This ecosystem-level approach mirrors enforcement strategies seen in other European markets, including the nine EU regulators who coordinated action against unlicensed prediction markets ahead of FIFA 2026.
The GGL's 2025 enforcement approach addressed multiple layers of the illegal gambling supply chain. The table below maps each target category to the regulatory rationale and primary enforcement tool applied.
| Enforcement Target | Regulatory Rationale | Primary Tool |
|---|---|---|
| Unlicensed operators | Direct illegal market participation | Blocking orders, cease-and-desist proceedings |
| Payment service providers | Enable revenue flows to illegal sites | Financial channel disruption, compliance notices |
| Software/platform suppliers | Provide infrastructure for illegal offerings | Third-party provider scrutiny, licensing conditions |
| Digital platforms (app stores, search) | Amplify visibility of illegal content | Cooperation requests, delisting coordination |
| Advertising intermediaries | Drive traffic to unlicensed operators | Advertising prohibition enforcement |
Targeting the full supply chain — rather than front-end operators alone — reflects a more sophisticated enforcement doctrine, one that the GGL appears set to deepen as it accumulates supervisory data across licensing cycles.
A Stronger Methodological Baseline for GGL Market Measurement
One of the more significant methodological decisions in the 2025 report is the GGL's deliberate move away from publishing its own standalone figures on the size of the illegal market. Instead, the authority anchors its assessment to an externally conducted scientific study — "Study of the Black Market and Canalization of Online Gambling Based on Surveys of Gamblers" — to ensure comparability and robustness.
That study, covering 2024 data, found that unlicensed and unregulated online gambling accounts for 23% of market volume. The inverse — the canalization rate — stands at 77%, meaning legal and regulated offerings represent more than three quarters of Germany's online gambling market.
A 77% canalization rate represents a meaningful benchmark, but it also frames what remains: nearly one in four euros wagered online in Germany still flows to unregulated operators.
The study will be continued, feeding into the ongoing evaluation of the 2021 State Treaty on Gambling.
77%
Germany's online gambling canalization rate (2024 data)
23%
Share of online gambling volume attributed to unlicensed/unregulated operators
2027
Year the new GGL licensing cycle begins
What 2026 Holds: GGL Evaluation and a New Licensing Cycle
The GGL frames 2026 as a pivotal year. The statutory evaluation of the 2021 State Treaty on Gambling is underway, a new licensing cycle begins in 2027, and the authority is committed to further developing data-driven and scientifically grounded supervisory instruments. The GGL's earlier joint statement on prediction markets illustrated how the authority is also engaging on emerging cross-border enforcement challenges beyond its core licensing remit.
Compliance Priority: Prepare Now for 2027 Licence Renewal
Operators holding GGL licences under the current cycle should treat the 2026 statutory evaluation as a forward indicator, not a background event. Historical precedent from other European re-licensing cycles — including the UK Gambling Commission's 2019 – 2021 review and Malta's 2021 framework refresh — shows that evaluation findings directly shape amended licence conditions. Teams should audit Safe Server data completeness, third-party provider agreements, and responsible gambling KPIs now, before the evaluation conclusions are published and conditions are set for 2027 applications.
Structural Maturity — and the Questions That Follow
The shift from licence issuance to active supervision signals that Germany's regulatory framework is entering a more demanding phase. For operators, this means greater scrutiny not just of their own compliance, but of the third-party service providers within their ecosystems. The GGL's decision to base market measurement on peer-reviewed methodology rather than internal estimates also raises the bar for how canalization claims can be scrutinised across the industry.
With the 2027 licensing renewal cycle approaching and the 2021 treaty evaluation in progress, operators and compliance teams should be monitoring whether the evaluation produces structural changes to licence conditions — and how enforcement priorities may shift as the GGL accumulates more granular market data. The Dutch market offers a useful cautionary parallel: the KSA's own market stagnation warnings show how a regulated share can plateau if enforcement gaps allow illegal operators to retain a structural foothold.
According to GGL.
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