Germany’s online casino sector has warned the new Chairman of the Glücksspielbehörde (GGL) to heed the advice given by his predecessor and focus on improving channelisation and combatting the black market without any intrusion on regulated licences.
The demand comes from the trade association of Deutscher Online Casinoverband (DOCV) following the transition of the Joint Gambling Authority of the Federal States (GGL) to the chairmanship of Christian Hochgrebe.
This July, the GGL’s Administrative Board rotated its annual chairmanship to the City-State of Berlin, appointing Hochgrebe to oversee the coordination of the regulator with Germany’s 16 Länder during a pivotal period for the country’s gambling framework.
New leadership for German gambling
Hochgrebe has taken office as the GGL prepares the first statutory review of the Fourth Interstate Treaty on Gambling (GlüStV 2021).
He stated that the regulator is “well prepared” for the next phase of the treaty’s development, with priorities centred on strengthening supervision of licensed operators and intensifying the fight against illegal gambling structures.
His predecessor, Sandro Kirchner, used the publication of the GGL’s 2025 Activity Report to acknowledge that Germany’s black market “cannot be completely eradicated” and acknowledged that “illegal services must be made more expensive and less attractive through enforcement measures”.
The DOCV has said that it understands Kirchner’s appeal for dialogue but cautioned that the GGL must not interpret compromise as easing enforcement against illegal operators.
The trade body has pointed to increasingly restrictive regulations that have been in place since the start of the GlüStV regime; it argued that such measures have reduced the attractiveness of Germany’s licensed market and bolstered the appeal of unlicensed operators.
“The GGL must not let up in its fight against the illegal market,” said Julia Lensing, Managing Director of the DOCV.
“An attractive legal market and consistent enforcement against illegal providers will move us forward. Licensed operators deliver youth protection, deposit limits and algorithm-based player monitoring, while illegal providers offer none of these safeguards and contribute no tax revenues.”
The association reiterated its willingness to work with regulators, policymakers and researchers to improve channelisation, calling for stronger website blocking, payment blocking, geoblocking and closer cooperation with search engines to restrict the promotion of unlicensed gambling services.
It has also renewed calls to modernise Germany’s criminal code to better prosecute cross-border online gambling offences.
Softening Controls
The debate comes as Germany has begun cautiously relaxing one of the most criticised provisions of the Interstate Treaty.
Since 1 July, licensed online casinos have been permitted to offer higher maximum stakes under strict conditions. Players aged 21 and over may wager up to €3 per spin, while a €5 maximum stake is available only to customers who complete a mandatory 90-day assessment period without displaying indicators of harmful gambling behaviour.
The DOCV welcomed the reform as a modest improvement but argued that many of the market’s most restrictive measures remain unchanged.
These include the nationwide €1,000 monthly cross-operator deposit limit administered through the LUGAS monitoring system, alongside extensive product restrictions that continue to differentiate Germany’s regulated market from many European jurisdictions.
As the Interstate Treaty enters its statutory review, advertising rules, deposit limits and wider consumer protection measures are expected to be examined. However, it remains unclear whether the Länder will consider revisiting broader product restrictions that the industry believes continue to undermine the competitiveness of the regulated market.
The effectiveness of Germany’s gambling regime remains fiercely contested. The GGL maintains that 77% of online gambling activity is channelled into the regulated market, representing approximately €1.8bn in gross gaming revenue, while estimating the illegal market generated €546.9m in GGR.
Both the DOCV and other industry stakeholders dispute those figures, arguing that channelisation has deteriorated significantly and may now have fallen below 50% as consumers migrate towards unlicensed offshore operators offering fewer restrictions and a broader range of products.
With Hochgrebe now overseeing both the treaty review and the GGL’s strategic direction, the outcome of the next phase of Germany’s gambling regulation is expected to hinge on whether policymakers can strengthen enforcement against illegal operators while restoring the competitiveness of the licensed market.
