DOCV warns that the latest GGL black – market estimates are ‘too conservative’, and the channelisation is still closer to 50%

(AsiaGameHub) –   Simon Priglinger-Simader, vice president of Germany’s Deutscher Online Casinoverband (DOCV) trade association, has rejected the GGL’s new 2025 channelisation statistics, labelling them as ‘conservative’ and incorrect.

The GGL released a report exceeding 120 pages last week, estimating Germany’s channelisation rate reached 77% in 2025. While the regulator evaluated different methods in the report, it ultimately conducted a survey of 2,000 people who had participated in online gambling (lotteries excluded) in the past year.

Survey participants were questioned on whether they had used illegal operators during that time.

Following his review, Priglinger-Simader stated the report was clearly flawed by “non-representative sampling,” indicating the sample did not properly reflect those gambling on the black market.

“Furthermore, there’s a degree of recall bias when you ask someone if they are engaging in illegal gambling. Most likely, they will say no,” Priglinger-Simader told iGB.

He added, “The figures are not in line with the tax revenue numbers we are aware of.”

DOCV-commissioned 2023 report still more accurate on black market size

In November 2023, the trade association published its own black market analysis, which found that as many as half of all players in Germany were using illegal sites. Priglinger-Simader asserts this assessment is more precise than the GGL’s most recent report.

“We still believe that, considering all the work done, a result showing a black market size of around 50% is much nearer to the real scale of the black market,” he continued.

The study was written by economist Gunther Schnabl from the University of Leipzig and utilised Nielsen gambling activity data to evaluate Germany’s channelisation rate.

This was merged with data on stakes placed on illegal sites, which Priglinger-Simader believes is probably significantly higher than current estimates indicate.

Although the GGL’s report stated black market Gross Gaming Revenue (GGR) was €547 million in 2024, the trade body head calls this number “too conservative.”

“We believe the real turnover of illegal operators is far greater due to the abundance of bonuses, absence of player safeguards, no loss limits, no spin limits—essentially no regulations in the black market,” he cautions.

He also points out that licensed German operators have received feedback from customers stating they have switched to the black market to escape the strict controls and limitations imposed by the regulated market.

“However, this information isn’t robust enough for a case study to incorporate it [into the next analysis],” says Priglinger-Simader.

Updated Schnable channelisation report expected soon

A revised report from Schnabl is anticipated this summer, analysing 2025 data.

“[They] are presently analysing 2025 figures using the Nielsen data panel from before and will produce an updated brief evaluation or perhaps a second edition of the study, possibly in June or July, around the summer,” Priglinger-Simader added.

Speaking on the report’s methodology, he said, “They will use a refreshed list of illegal websites targeting Germany. Then it’s essentially an update incorporating new illegal operators that have entered, along with the overall market evolution. For 2025, they have already compiled an updated list of illegal operators, as that landscape is very fluid and has changed over the past two or three years.”

Despite dismissing the GGL’s latest figures, Priglinger-Simader concedes that the regulator’s lowered channelisation estimate is a good indication it is beginning to comprehend the market better.

Channelisation rate could be used to prevent Interstate Treaty review updates

Back in June 2024, the regulator indicated the black market constituted only about 4% of the total sector.

Priglinger-Simader is concerned, however, that this new data might be leveraged to the regulator’s advantage during the current review of the German Interstate Treaty regulations.

This review represents the licensed industry’s sole opportunity for easing player restrictions such as compulsory deposit limits and slot stake limits.

He cautions that the GGL could “use [the data] to claim everything is functioning perfectly, that no action is needed to bolster the legal [framework], and that licensed operators should simply carry on as before.”

The review is scheduled to finish next year.