Strengthening Germany’s Fight Against Illegal Online Gambling: The Push for Faster, More Flexible Action
Strengthening Germany’s Fight Against Illegal Online Gambling: The Push for Faster, More Flexible Action
Introduction: A Regulator at a Crossroads
Germany’s joint gambling regulator, the Gemeinsame Glücksspielbehörde der Länder (GGL), is publicly acknowledging a fundamental problem: it cannot keep up with the rapidly evolving illegal online gambling market. In an interview published on 22 September 2026 with the Mitteldeutsche Zeitung, GGL executive board member Ronald Benter argued that the authority needs more discretionary power to respond to new threats and implement decisions without waiting years for treaty amendments.
This call for change is not merely bureaucratic. It reflects a growing gap between the legal framework—primarily the Interstate Treaty on Gambling (GlüStV 2021)—and the aggressive, often cross-border operations of unlicensed providers. This guide explains why the current system is slow, what the GGL is proposing, and how a recent major police action illustrates the challenges and possible paths forward.
Understanding the Regulatory Landscape
What Is the GGL?
The GGL is the joint gambling authority of Germany’s 16 federal states (Länder). Established under the GlüStV 2021, it is responsible for enforcing gambling laws across the country, including licensing, supervision, and combating illegal gambling. Its tasks include blocking illegal websites, freezing payments, and coordinating with public prosecutors.
The Interstate Treaty on Gambling (GlüStV 2021)
The GlüStV 2021 is a multi-state treaty that harmonizes gambling regulation in Germany. It sets detailed rules on everything from sports betting and online slots to poker and advertising. While it provides a uniform framework, its very specificity is now seen as a liability.
The Core Problem: Treaty Amendments Take Years
Why Revision Is So Slow
As Benter noted, the treaty contains “very detailed rules.” Any change—whether to expand enforcement powers, adjust licensing conditions, or tackle new gambling formats—requires a new treaty amendment. This process involves negotiations among all 16 federal states, followed by ratification in each state parliament. Even when the GGL and the states agree on the need for change, the amendment can take several years to complete. In a market that changes on a monthly basis, this timeline is untenable.
The Dynamic Illegal Market
Benter stressed that “the illegal market is very dynamic.” Unlicensed operators constantly shift their hosting, payment methods, and advertising channels. They target German users from jurisdictions with lax regulations. The GGL, bound by a static treaty, often finds itself reacting to situations that have already evolved. As Benter put it: “Ultimately, we have the expertise and should therefore also be able to react faster to developments and decide on new measures.”
Proposed Solution: More Leeway with State Oversight
Giving the GGL Room to Maneuver
Benter’s primary request is for the GGL to receive broader discretionary authority. Instead of waiting for treaty changes, the regulator should be able to implement new measures—within agreed boundaries—and adjust its approach as market conditions demand. However, he is not asking for unfettered power. The GGL’s decisions would still be made in consultation with its administrative board (Verwaltungsrat), where the interests of the federal states are represented. This board is currently chaired by Christian Hochgrebe, Berlin’s state secretary for the interior, who assumed the role on 1 July 2026. This structure would preserve the necessary democratic oversight while allowing for more agile enforcement.
The Ongoing Treaty Evaluation
The GGL sees a practical route forward in the ongoing evaluation of the GlüStV 2021. This evaluation—a built-in review mechanism—offers a window to propose targeted reforms. Benter’s interview is part of a broader lobbying effort to ensure that the evaluation results in real change, not just more deliberation.
The Criminal Law Dimension: Targeting Operators Abroad
A Gap in Enforcement
A key area where the GGL seeks reform is criminal law. Currently, public prosecutors can open proceedings against individuals who offer illegal gambling to German users from outside the country. However, Benter noted that “this has almost never happened so far.” The practical difficulties are immense: jurisdiction, evidence gathering across borders, diplomatic sensitivities, and the sheer anonymity of online operations.
Why More Prosecutions Matter
The GGL believes that criminal proceedings would act as a significant deterrent. Civil enforcement (such as payment blocking and website takedowns) is reactive and can be circumvented with technical workarounds. Criminal charges, on the other hand, carry the threat of personal consequences—arrest, extradition, and asset forfeiture. Even if successful prosecutions are rare, visible investigative action can deter potential operators.
A Case Study: The Frankfurt Round-Up
The Raid of 9 September
On 9 September 2026, Frankfurt prosecutors announced a major operation. Eleven properties in the Rhine-Main region, mostly in Frankfurt, were searched. Over 100 officers participated, and one main suspect was arrested on a warrant. Five individuals were suspected of offering online gambling without a German licence since at least July 2021—allegedly on a commercial, gang-like basis.
The Scale of Alleged Criminality
The numbers are staggering. Between July 2021 and the end of 2023, the platforms processed an estimated €5.86 billion in stakes. For 2024 alone, the suspected tax loss amounts to around €77.6 million. Investigators secured assets worth approximately €82 million. This case illustrates exactly why the GGL argues for faster processes and stronger cross-border powers—by the time the investigation concluded, the operators had been active for years.
The GGL’s Role
In a statement on 17 September, the GGL welcomed the operation. It highlighted its own contributions: sharing intelligence gathered through payment blocking, network blocking, and measures against illegal advertising. The GGL also reiterated its call for lawmakers to place greater emphasis on criminal law as a tool against illegal gambling, rather than relying solely on administrative enforcement.
Implications and Outlook
What Would “More Leeway” Mean in Practice?
If the GGL receives the discretion it seeks, it could:
- Adjust enforcement priorities without waiting for treaty revisions.
- Introduce new technical or administrative measures in response to emerging tactics (e.g., crypto-based payments).
- Collaborate more closely with prosecutors and international partners.
- Communicate more openly with licensed operators and the public about evolving rules.
Potential Concerns
Critics might worry that giving the GGL more autonomy could lead to inconsistent enforcement across states or overreach. However, the administrative board’s oversight is designed to mitigate this. The challenge will be balancing agility against accountability.
The Road Ahead
The ongoing evaluation of the GlüStV 2021 provides a pivotal moment. Benter’s public statements are part of a strategic push to ensure that the reform debate prioritizes operational flexibility. The Frankfurt case serves as a powerful argument: the longer it takes to adapt rules, the more money flows to illegal operators and the more taxes are lost.
Conclusion
Germany’s gambling regulator is at a turning point. The legal framework designed to ensure safe and fair gambling is struggling to cope with a dynamic, often internationally based illegal market. Ronald Benter’s call for more leeway is not a bid for unchecked power, but a pragmatic plea for the authority to use its expertise effectively. With the backing of the federal states and a clear-eyed view of the enforcement gaps, Germany may finally be moving toward a regulatory system that is as nimble as those it seeks to police.
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