German Regulator Seeks Dialogue on Black Market as Illegal Games Dominate Searches
The German regulator's enforcement head called for more talks with suppliers to understand why popular games are missing from the licensed market.
Nadja Wierzejewski, Head of Enforcement at Germany's Joint Gambling Authority (GGL), called for more involved conversations with suppliers to understand how and why games land on the black market.
Wierzejewski said a key question is differentiating the interpretation of channelisation, asking whether the goal is to channelise players, money, or both.
Her wishlist also included winning litigations against Meta and Google to set an example for others.
The call comes as data presented at the Gaming in Germany conference highlighted the scale of the illegal market.
Jeffrey Haas, Chair of Blask Business Intelligence, revealed that 68% of German online gambling searches go to illegal operators.
Haas added that two unlicensed brands, Vulkan Vega and NV Casino, hold 61% of brand-specific searches.
Crash games, particularly Aviator, are among the most searched-for games but are not found on licensed operators' platforms.
Haas further noted that three in four offshore operators run live casino, compared to only two of the 63 licensed German operators.
Discussions at the conference also turned to regulatory reforms in neighboring Austria, which is transitioning from a state monopoly to a multi-licence regime.
Dr. Christian Rapani, Partner at Rapani Rechtsanwälte, advised operators to prepare thoroughly for strict background checks.
"It all depends on self-disclosure. If it is not satisfactory, you might find yourself in an uphill battle against the regulator to prove that your figures are correct," Rapani said.
The Austrian regulator will review a minimum of seven years of an operator's historical tax liabilities and outstanding player-related court cases.
The reforms, aimed at addressing channelisation rates of 30%-50%, are scheduled to begin on January 1, with a full market rollout in October 2027.
The Austrian government may face a challenge from Malta over the reforms, as historic liability provisions could conflict with Malta's Bill 55, which protects its licensees from EU legal claims.
Prof. Dr. Christian Piska of the University of Vienna criticized overregulation, arguing that player protection is not a justification for strict but ineffective rules.
"It’s about creating a market that is attractive enough to keep players in it. If you don’t take this into account, you defeat your own purpose," Piska said.
He argued that monopolies keep rivals out, not gamblers in.
The conference also addressed the legality of prediction markets in Europe, a vertical with a global value estimated to reach $88 billion in FY26.
Dr. Matthias Spitz, Senior Partner at Melchers Law Firm, and Dr. Christian Rapani noted that most EU gambling authorities view prediction markets as a gambling offer rather than a financial instrument and are against them.
Rapani added that Austria is one of the few states that distinguishes between federally regulated games of chance and state-regulated betting.
