A new study on the German online gambling market concludes that the black market remains an economically significant segment. Its core significance lies not only in a new scale but, above all, in the methodological classification: The authors first demonstrate that previous estimates of the black market sometimes differ significantly from one another, often capture only partial aspects, and are highly sensitive to data quality and model assumptions. For this reason, the study advocates that the market should not be assessed using a single approach in the future, but rather various methods and updating them regularly.
In the second part, the study draws on its own online survey of 2,000 active online gamblers, which was conducted in November 2024 via a German panel provider. The survey covered sports betting, virtual slot games, online casino games, and online poker. Although online lotteries were included, they were not the focus of the analysis due to their comparatively lower risk profile. At the same time, the authors themselves emphasize that this is a non-representative survey of an exploratory nature.
The survey results paint a clear picture. Of a total of 4,027 provider mentions, 20.3 percent were for unlicensed offerings. Even more striking, however, is the structure of the market: while the share of mentions is around one-fifth, 74.6 percent of the clearly named providers were unlicensed. This suggests that the regulated market is more heavily concentrated on a few well-known brands, while the unregulated sector appears significantly broader and more fragmented.
From the study’s perspective, the financial metrics are particularly relevant. Here, the <black market remains at a high level not only in terms of mentions but also in terms of wagers and losses. According to the analyzed data, 22.38 percent of total wagers and 22.97 percent of total losses are attributable to unlicensed platforms. At the same time, users of such platforms reported higher average monthly wagers and higher average monthly losses.
In addition, around one-third of respondents had come into contact with unlicensed providers—either exclusively or in parallel with licensed offerings. According to the study, it is precisely this mixed usage that is associated with increased gambling intensity and higher financial burdens.
Based on this data, the study also derives an estimate of the market volume. Since, from the players’ perspective, gambling losses correspond to the providers’ gross gaming revenue, the study uses precisely this value as its central benchmark. This results in a model-based estimate for the unlicensed segment of approximately 466 million euros for 2023 and approximately 547 million euros for 2024. The authors explicitly view these figures as approximations, not as definitive measurements.
This is precisely where the study’s true significance lies: it aims not only to quantify the black market but also to highlight it as a distinct market segment with its own usage and risk patterns. At the same time, it clearly acknowledges its limitations. The data is based on self-reported information, retrospective data covering up to twelve months, and a non-representative panel sample. Memory errors, inaccurate provider attributions, and biases in participation may influence the results. Nevertheless, the study provides an important behavior-based perspective on a market that can only be incompletely captured using purely technical or revenue-based methods.
Ultimately, the study makes two key points: The black market in German online gambling remains significant, and monitoring it requires more than a single metric. There is a need for ongoing monitoring that combines surveys, market data, and other measurement methods. The report is therefore not intended to be the final word in the debate, but rather a foundation for more accurate and regular measurement of the unregulated market.
The full study, “Measuring the Black Market for Online Gambling in Germany,” is available for download here as a PDF.