Germany's gambling regulator has moved decisively from the licensing phase into structured supervision – and the numbers suggest the shift is paying off. The Gemeinsame Glücksspielbehörde der Länder (GGL) has released its Activity Report 2025, documenting how enforcement and oversight measures against both licensed and illegal operators developed over the year.
From Licensing to Supervision: GGL's 2025 Priorities
The GGL's Activity Report 2025 confirms that the regulator's focus has shifted from onboarding operators to sustained supervisory practice. For the first years following the introduction of the Gambling State Treaty 2021, the GGL's priority was granting permits to operators entering the regulated market. That emphasis changed markedly in 2025. The regulator's central tools now include supervisory dialogues, case-triggered interventions, and proactive measures based on tips and market observation. The GGL, which also recently joined eight other authorities in a joint statement on unlicensed prediction markets, continues to expand its cross-border enforcement posture. According to the report, internal cooperation between the GGL's specialist departments has intensified, contributing to a more consistent supervisory practice across the board.
Safe-Server Enforcement and Data Infrastructure
Technical infrastructure remained a priority throughout 2025, with Safe-Server enforcement identified as a demanding but essential compliance area. The GGL continued expanding its systems to build a reliable, comparable data foundation for supervision, analysis, and future regulatory decisions. Enforcing the mandatory and correct use of Safe-Servers by licensed providers proved to be a demanding process during the year – but one the regulator considers essential groundwork for improving data quality across the market.
Targeting the Illegal Market's Wider Ecosystem
The GGL's approach to combating illegal online gambling was sharpened in 2025, expanding beyond individual operators to include service providers connected to illegal offerings. Rather than treating unlicensed platforms in isolation, the regulator now addresses them within their broader market and process context. This mirrors a wider regional pattern, where illegal market share remains a persistent challenge — in the Netherlands, for instance, illegal operators now control nearly half the market. Close cooperation with platform operators also continued throughout the year, aimed at reducing the visibility of illegal content in digital spaces.
Market Measurement Grounded in Science
The 2025 report does not include independent figures on the size of the illegal market for that year, relying instead on prior scientific study data. Instead, the GGL relies on findings from its scientific study, Study on the black market and channelization of internet gambling based on a survey of gamblers. That study, covering 2024, found that unlicensed and unregulated online gambling accounted for 23% of market volume – yielding a channelization rate of 77%, meaning legal, regulated offerings make up more than three-quarters of Germany's online gambling market. The study will continue, feeding into the ongoing evaluation of the Gambling State Treaty 2021.
Looking Ahead to 2027
With the GGL approaching its fifth year of operation, 2026 will bring the legally mandated evaluation of the treaty framework, preparation for a new licensing cycle beginning in 2027, and further strengthening of data-driven, science-based supervisory tools. Comparable regulatory transition points are visible elsewhere too, such as Malta's tax reform briefing ahead of October changes, which similarly signals that operators should prepare early for framework shifts.
What Operators Should Watch
The pivot from licensing to sustained oversight signals that regulatory scrutiny for permit holders will only intensify, not ease. Operators should expect Safe-Server compliance to remain a recurring audit point, given the GGL's explicit framing of it as unfinished business.
A 77% channelization rate is a meaningful benchmark – but its durability depends on how the GGL's expanded targeting of service providers around illegal operators plays out in practice.
The extension of enforcement to service providers – payment processors, marketing partners, and infrastructure vendors – broadens compliance exposure well beyond licensed operators themselves. Ahead of the 2027 licensing cycle, firms across the supply chain should anticipate closer scrutiny of their German-facing partnerships, and treat the evaluation period as a signal to review data reporting practices now rather than later.
According to GGL.
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