Regulatory bodies Since 1st July 2022, the Joint Gambling Authority (“GGL”) has gradually replaced the Saxony-Anhalt State Administration Office as the body charged with taking action against unlicensed cross-state operations and activities across Germany. The regulator can carry out their supervision through various measures. For one thing, operators are required to report on a regular basis about various facts and figures in relation to their operations. Reporting requirements require figures regarding players, stakes, turnover, etc., as well as findings on results and consequences of their advertising as well as safer gambling ambitions & measures. Furthermore, the authority could at any time request more detailed documents and evidence on the information. Additionally, the regulator is able to monitor certain game-related facts in any case, because operators have to be connected to LUGAS (player activity monitoring, limit monitoring) and OASIS (nationwide player barring database). The operator is liable for breaches of gambling regulations, but liability may also extend to advertising partners and PSPs and affiliated companies. The GGL have the option to publish the names of operators reprimanded for breaches of regulation on a ‘naming and shaming’ list on their website. Illegal gambling as well as advertising for games that have not been licensed are triggers for enforcement. Still, branding of unregulated operations remains visible in some sports competitions available to German audiences, such as Formula 1 broadcasts. Furthermore, allowing payment methods that do not correspond with current AML-regulations trigger enforcement measures. Tax liabilities do so, as well. According to the regulator's activity report for 2024 (published June 2025), GGL issued 231 cease-and-desist proceedings that year, 83 of which related to the operation of illegal gambling and the remainder to advertising for illegal games of chance; the regulator's activity report for 2025, published 3 July 2026, records that by the end of 2025 a cumulative 1,843 illegal websites had become unreachable from Germany as a result of cease-and-desist orders or network blocking, 2,662 websites of illegal operators or advertisers had been reviewed, and 178 payment-blocking measures had been carried out. These figures should be used in preference to any differing trade-press figures elsewhere in this document purporting to describe the same 2025 report. "Unauthorised gambling”, meaning non-German licensed gambling operations, and related advertising can be enforced against based on administrative law, administrative offence law or criminal law. Potential sanctions range from paying a fine to a worst-case imprisonment of three months to five years. In administrative offence and criminal law, profits may be “skimmed off” under certain conditions. The GGL have tried forcing the hand of local prosecutors in the city of Halle i.e. the prosecutor’s office at the seat of the authority by filing hundreds of criminal charges against unregulated online operations, however, the regulator admitted in their annual report that many of them had been dismissed because that prosecutor did not consider the criminal charges to be enforceable against offshore operators. Trade bodies of licensed operators therefore have called for more effective enforcement against the black market. Betting: Online sports betting is not a key enforcement priority for German regulators. Since the start of the licensing process for sports betting in 2020, the former Hessian regulator had assumed a centralised responsibility for regulating sports betting which should bar other regulators from having a divergent enforcement approach. The GGL has established a system of pre-approval of new bet types and markets to be offered, giving the regulator the opportunity to prevent non-compliant bet types and markets at an early stage. As a consequence, betting on sports events or competitions that may be susceptible to match-fixing, such as amateur sports and lower leagues, is banned. With respect to preventing match-fixing, licensed operators are required by the GGL to participate in an early warning system, such as the International Betting Integrity Association, again trying to prevent match fixing issues at an early stage. Bingo: Since bingo falls under the state monopoly, there is almost no enforcement against bingo operators. Casino: In principle, regulatory enforcement against unauthorised operations and distributions differs in the states and some “hardliner” states such as Saarland had issued far-reaching interdiction orders in 2020. In addition, it is possible for gambling regulators under the Interstate Treaty to authorise each other to furnish one interdiction procedure for multiple states and law enforcement seems to be on the rise lately. The Gambling Acts of the individual German states authorise regulators to sanction illegal gambling and related advertising as an administrative offence with administrative fines. The value of fines that can be imposed can be up to EUR 500,000 as per the various Gambling Acts of the German states. Liability for administrative offences does not only pertain to legal representatives of companies who are personally involved in unlawful behaviour of the company but may also lie with the legal entity represented by that individual. In contrast, liability under the German Criminal Code only pertains to individuals and not to legal entities. Lottery: Since the lotteries fall under the state monopoly there is almost no enforcement against lottery companies, except in the case of so-called “secondary lotteries” which – unlike lotteries and sports betting – may not be operated or brokered on the internet. Secondary lotteries clearly have been an enforcement priority for German regulators for over a decade. Poker: The GGL generally claims to enforce against illegal online operations, though cases of enforcement against online poker operations have not become publicly known as yet. Skill games: Skilled games fall outside of the scope of German gambling laws. It appears as if the regulator’s enforcement efforts are currently not focused on the skill game sector, though GGL officials have indicated that their authority may take a closer look at the skill games sector in the near future to ascertain that skill games operations do not veer into the gambling sector. Software/B2B: Software and B2B suppliers fall outside the scope of German gambling laws. Still, the GGL continually reviews compliance of games and software used in licensed operations, though the any issues will usually be addressed with the licensee and not with software / B2B supplier (the exception being PSPs where the regulator is supposed to address issues directly with the PSP under the regulations).
Germany · Question 10 of 11
Enforcement: How hard does the regulator enforce?
Mixed · Confirmed · Expert approved · 3 post-review updates · Not reviewed · In expert review scope · Back to full Germany report →
Key section parameters
| Jurisdiction | Germany (DE) |
|---|---|
| Regulator | Recorded in register |
| Favourability | Mixed |
| Confidence | Confirmed |
| Review status | Expert approved · 3 post-review updates · Not reviewed · In expert review scope |
| Last collected | 23 Oct 2026 |
Summary answer
Regulatory bodies Since 1st July 2022, the Joint Gambling Authority (“GGL”) has gradually replaced the Saxony-Anhalt State Administration Office as the body charged with taking action against unlicensed cross-state operations and activities across Germany. The regulator can carry out their supervis…
Germany's gambling enforcement regime rests on the permit requirement in GlüStV 2021, with the Gemeinsame Glücksspielbehörde der Länder (GGL) empowered to issue orders against unlicensed operators on that statutory basis. That mechanism suffered a material setback in 2026: the Verwaltungsgericht Halle blocked three GGL enforcement directives, in decisions of 6 August (7 B 491/25 HAL, 7 B 492/25 HAL) and 24 August (7 B 62/26 HAL), each citing a structural deficit in the evidentiary and data-access basis the GGL relied upon. The rulings constrain how the GGL can use its permit-requirement enforcement tool against unlicensed operators without altering the underlying statutory prohibition. In response, a GGL board member has publicly called, within the context of the ongoing GlüStV evaluation, for expanded and faster-acting decision-making powers to address what was described as a highly dynamic illegal market. That call is a public institutional position tied to a live evaluation process due by 31 December 2026, not yet a statutory change. Together, the court decisions and the GGL's public response point to a widening gap between the authority's enforcement mandate and its current practical capacity to exercise it against unlicensed operators.
GGL enforcement intensity against unlicensed online gambling operators has risen sharply: prohibition proceedings increased from 68 in 2022 to 287 in 2025, and approximately 6,300 websites had been reviewed by end of 2025 for illegal gambling offers or associated advertising, a more than fourfold increase in proceedings within three years. Separately, the Bundesgerichtshof designated case I ZR 216/25 a Leitentscheidungsverfahren, with a hearing held 17 September 2026 on whether players may reclaim losses from operators that lacked German authorisation. Numerous stayed cases await this outcome, meaning the ruling will apply well beyond the individual case. The two developments together point to intensifying enforcement exposure on two fronts: rising administrative prohibition activity against unlicensed operators, and a pending judicial determination of retrospective civil liability for historical unlicensed play. No specific licence-revocation event was evidenced this cycle against a currently licensed GGL operator; the enforcement pressure described here is directed at unlicensed or historically unlicensed activity rather than at compliant licence-holders.
GGL imposed a confirmed €250,000 coercive fine (Zwangsgeldbescheid) on the rapper Capital Bra for livestreamed promotion of illegal online gambling, an enforcement action targeting promotional and affiliate-style intermediary conduct rather than an operator directly. GGL also intensified enforcement tied to the 2026 World Cup, probable to include international regulator cooperation with the IOC, FIFA and UEFA on information exchange concerning illegal betting, confirming that major sporting events function as enforcement trigger points within the German system. Both actions sit within Germany's civil-law enforcement-theory pattern: unlicensed gambling activity is itself an offence under GlüStV 2021 §4, prosecuted primarily through administrative rather than criminal channels, with accessory liability extending to intermediaries who promote illegal operators. No enforcement action against a licensed operator's core betting product surfaced this cycle; the escalation is concentrated on promotional actors and offshore illegal-market activity around a major event window.