From ICE 2025: A look at the German gambling market

In summary

The industry is observing the German gambling market with growing concern. Democratic institutions are struggling to find the right path forward and there are increasing calls for a more effective regulatory framework.

First impressions

Visitors to ICE 2025 are swept away by the vibrant energy of an industry celebrating itself in a perfectly organised environment.

However, in various lectures and especially in informal conversations within trusted circles, the industry underlying worries are clear. In particular, the view of the German market from an international perspective ranges from surprise to confusion.

What direction are the major European markets heading in? How will upcoming changes in governance in key democracies affect the industry? Is Germany getting its own way even in a regulated environment?

After a full day of first impressions at ICE 2025, this article explores the major discussions and attempts to connect broader political trends to the gambling market in Germany in a somewhat daring way.

Paradigm shift

We are witnessing the limits of the complexity of global and state systems. Warlike states and national self interest are reshaping the world order. Market and societies are undergoing profound changes. Globalisation is being declared over, and we are standing on the threshold of a new era defined by particularism.

The financing of wars, boosting economic competitiveness and achieving social balance are the central issues in the ongoing struggles between political parties for control. Topics like tax cuts, rising military expenditures and the tension between military spending and social issues such as universal basic income, dominate the headlines and drive the conflicts between political factions.

Political parties are drifting apart and paradigms that were thought to be certain are being swept away in the wake of the voters' will. Just as global complexity is causing entire states to falter, state institutions are reaching their limits.

Calls for less bureaucracy are growing louder. This is not just about regulation in isolation, which is, in many ways sensible. At the ballot box, it is about the future and existential fears about job security, competitiveness and the growing influence of global super corporations that are actively intervening in domestic politics.

Europe

Our legal system operates under European guidelines. The German implementation often imposes more restrictive competition rules than neighbouring countries. Whenever we take charge of shaping a policy area, we can count on Europe eventually creating a lighthouse project at least in terms of regulatory details.

It is important to note that Germany should be grateful to Europe for its framework. Mistakes are made in the way regulations are implemented here. With an expected growth rate of 1% of the GDP in 2025, Germany will lag behind the most other European countries. German institutions are struggling to seize opportunities to gain a competitive edge within the country.

It is high time to integrate alternative European solutions and experiences into Germany´s approach. Success models, such as Italy’s new tax system for regulated gaming based on gross gaming revenue, are just one example of what could work in Germany.

Dangers for regulated gaming

In the 2000s, the JMStV introduced technical youth media protection measures by creating closed user groups. This overregulation weakens the industry’s competitiveness in Germany and allowed pornography to infiltrate the media environment, which now reaches children. Global providers, largely out of reach of German regulation, have increasingly circumvented national controls. This failed regulatory approach resulted in a sexualised media environment for children.

These lessons can’t simply be applied directly to regulated gaming. However, the parallels are more than coincidental.

The GlüStV 2021 aimed to open the market and channel gaming in a positive direction while combating the black market. However, it is leading to a decline in tax revenues in Germany, even as tax revenue is increasing in comparable European countries. This serves as evidence of a growing black market.

One must ask whether the current strategy of taking action against regulated providers, fine-tuning regulations with additional provisions, technical specifications, and a wide range of state ordinances, is undermining the intent of the GLüStV to create sustainable regulation.

Overall, regulated gaming appears to be moving backward. The result is a loss of competitiveness compared to other European countries, declining tax revenues and reduced protection for minors and players.

Struggling for the right path

Players have the right to engage in gaming and win in legal environments with competitive providers. At the same time, minors and individuals struggling with addiction must be protected, both by the state and by regulated providers.

The federal states are in constant competition, and struggle in legal conflicts over the best way to channel gaming. Their daily operations, influenced by their discretionary powers, create a dynamic shaped by individuals and small groups of stakeholders.

This system of politics, where rulers govern over the ruled, is an essential part of our legal structure. However, once state action deviates from its legal framework, the system becomes unbalanced. Sustainable, sound regulation ensures continuity and stability beyond the political cycle.

Summary & Conclusion

Confidence in a good legal framework will only emerge when players can pursue their interests with adequate protection, when legal providers can operate sustainably in the face of competition, and when institutional pressures are eased. In this case, regulation works.

It’s time to focus on our strengths. This includes leveraging national discretion within the framework of European regulation, and implementing national measures that increase tax revenues while ensuring effective protection for players and minors.

If we get the direction right, we can look forward to a functioning market, new early detection technologies, improved offerings from providers, and rising tax revenues.

At ICE in Barcelona, we are discussing the major trends affecting the industry: the integration of terrestrial and online gaming, new marketing strategies at IGB, and the overarching use of artificial intelligence. With renewed energy, fresh ideas, and strong motivation, we will tackle the challenges in our domestic market.