Assessing the Black Market for Online Gambling in Germany: Study Completed and Published
We are pleased to announce the successful completion and publication of our empirical study “Measuring the Black Market for Online Gambling in Germany”, conducted by the Blockchain Research Lab and funded by the Gemeinsame Glücksspielbehörde der Länder (GGL ; engl. Joint Gambling Authority of the Federal States).
The study was carried out throughout 2024 until April 2025. It represents the first comprehensive attempt in Germany to combine a critical methodological review with a survey of gamblers to assess the size, structure, and dynamics of the illegal online gambling market.
A Novel Approach to Measuring the Black Market
Building on earlier research, the study follows a two-part approach:
- Part I systematically evaluates existing methodologies used to estimate the size of the black market, including web traffic analysis, behavioral data, proxy variables, and surveys.
- Part II introduces a novel bottom-up approach based on a non-representative survey of 2,000 gamblers, providing direct insights into gambling behavior, spending patterns, and platform usage.
This combination allows for a more robust and nuanced understanding of the black market, addressing key limitations of previous estimation approaches.
Key Finding: Black Market is Significant but not Dominant
The results confirm that while the regulated market constitutes the majority of online gambling activity in Germany, the black market remains economically significant:
- Around 20.3% of reported gambling providers used by respondents were unlicensed.
- 22.4% of total stakes and 22.97% of total losses were attributed to illegal providers.
- The estimated gross gaming revenue of the black market reached €547 million in 2024.
These findings highlight that illegal operators capture a slightly disproportionate share of gambling expenditure relative to their number.
Differences in Use Patterns and Risk Profiles
The study identifies several statistically significant differences in gambling behaviour between licensed and unlicensed providers. Gambling on unlicensed platforms is associated with higher stakes per session, higher monthly losses, longer session duration, and higher playing frequency. These results indicate that, across multiple behavioural dimensions, gambling activity on unlicensed providers is more intense.
While users of unlicensed providers also show higher average PGSI scores and the highest observed share of problem gambling (around 53% among exclusive users), these differences, however, are not statistically significant. Overall, 50% of online gamblers fall into the highest PGSI risk category.
Highly Diverging Awareness of License Status
The study also examines whether players consider licensing when selecting providers. Respondents were asked whether they pay attention to whether an online gambling provider holds a German licence. Overall, 58.8% reported that they do. However, responses differ markedly by user group: 72.8% among users of only licensed providers, 47.2% among users of both licensed and unlicensed providers, and 13.7% among users of only unlicensed providers.
Advancing Measurement and Monitoring
A central contribution of the study lies in advancing the methodology to measure and monitor the black market for online gambling. By combining established top-down estimation approaches with a bottom-up survey of 2,000 gamblers, the study demonstrates how different data sources can be systematically triangulated to improve robustness and reduce methodological bias. The survey captures behavioral variables such as monthly stakes, monthly losses, session-based activity, and provider choice, enabling both relative market share estimation and the extrapolation of absolute market size. In doing so, the study establishes a foundation for regular, longitudinal monitoring of the black market and highlights the importance of integrating behavioral data, improved correction methods, and emerging data-driven technologies into future measurement frameworks. This integrated approach enables more accurate and policy-relevant assessments of the size and dynamics of the illegal online gambling market.
Looking Ahead
Despite the limitations of a non-representative survey, this study allows important insights into the online gambling landscape in Germany and advances the methodology of its continuous monitoring. It underscores the need for continuous data collection and ongoing methodological refinement, particularly given the dynamic nature of online markets and the limitations inherent in survey-based approaches. Future research should build on this work through repeated panel-based surveys and integrated monitoring systems, allowing policymakers and regulators to track developments over time and to more effectively evaluate the impact of regulatory and enforcement measures.
The study can be downloaded here.