In a 4 November interview with GlücksWirtschaft, German Online Casino Association (DOCV) managing director Julia Lensing challenged the Joint Gambling Authority of the Länder’s (GGL) estimate that unlicensed online gambling represented 22.97% of the German market in 2024. The GGL’s study, based on a survey of gamblers, calculated a 77.03% channelisation rate.
Different measures, competing claims
Lensing cited an H2 Gambling Capital estimate that 64% of German players use illegal offers and an unpublished update to a 2023 access-time study which, she said, put the illegal share of online gambling time at 57% in 2025. These figures measure different things and are association-reported claims, not directly comparable estimates of market revenue. Lensing also referred to Frankfurt investigations involving almost €5.86bn in stakes at one suspected illegal provider over two and a half years.
What DOCV wants changed
The association is calling for the GGL to publish more underlying market data, a more consistent nationwide online-casino licensing route, changes to virtual-slot taxation and stronger action against offshore operators. The debate matters to affiliates assessing Germany, but the DOCV’s estimates should not be presented as official market statistics.