DOCV Vice President Simon Priglinger-Simader believes GGL’s black market study suffered from ‘non-representative sampling’ and ‘recall bias’ in its methodology.
Key takeaways:
- DOCV vice president Simon Priglinger-Simader says the GGL’s latest black market study understates the scale of illegal gambling in Germany, arguing its survey methodology likely missed a significant share of black-market users.
- The GGL estimates Germany’s 2025 channelisation rate at 77%, but Priglinger-Simader says the real figure is likely closer to 50%.
- The debate goes beyond methodology, as higher official channelisation figures could reduce pressure on the regulator to ease player restrictions in Germany’s Interstate Treaty review.
Simon Priglinger-Simader, vice president of the Deutscher Online Casinoverband (DOCV) trade body in Germany, has dismissed new 2025 channelisation figures from the GGL as ‘conservative’ and inaccurate.
Last week, the GGL published a 120+ page report which estimated Germany’s channelisation rate hit 77% in 2025. The regulator assessed various methodologies within the report, but chose to operate a survey involving 2,000 individuals who had engaged in online gambling (excluding lotteries) within the previous 12 months.
Within the survey, players were asked whether they had played via illegal operators during the period.
After assessing the report, Priglinger-Simader said it clearly suffered from “non-representative sampling”, meaning the sample used did not accurately represent those playing via the black market.
“Also, we see a bit of recall bias when you are asking someone about whether they are participating in illegal gambling? Well, most likely [they will say] not,” Priglinger-Simader tells iGB.
“The numbers are not consistent with the observed tax numbers we know,” he adds.
Why it matters:
- If the GGL concludes most players are already gambling within the licensed market, it may have less incentive to ease restrictions such as deposit and stake limits. However, licensed operators argue current restrictions are pushing customers to illegal sites.
DOCV-commissioned 2023 report still more accurate on black market size
In November 2023, the trade body released its own black-market study, which determined up to half of players were using illegal sites in Germany. Priglinger-Simader says this estimate is more accurate than the GGL’s latest report.
“We still think with all the work that has been done there and a result of around 50% black market size, we are still much closer to the actual size of the black market,” he adds.
The study was authored by economist Gunther Schnabl of the University of Leipzig and used gambling activity data by Nielsen to assess Germany’s channelisation rate.
This was combined with stakes spent on illegal sites, which Priglinger-Simader says is likely much higher than estimates even suggest.
The GGL’s report said that black market GGR reached €547 million in 2024, but the trade body chief says this figure is “too conservative”.
“We think the actual turnover of illegal operators is much higher because of the massive number of bonuses, the lack of player protection, no loss limits, no spin limits, nothing at all in the black market,” he warns.
He also notes that licensed operators in Germany have even received updates from customers warning they have moved over to the black market to avoid the stringent checks and restrictions placed on them by the licensed market.
“But this data is not strong enough for a case study to include this [in the next study],” says Priglinger-Simader.
Updated Schnabl channelisation report expected soon
An updated report from Schnabl is expected in the summer which analyses data from 2025.
“[They] are currently analysing 2025 numbers via the Nielsen data panel from last time, and will come up with an updated short assessment or even a second version of the study, maybe in June, July, somewhere around the summer,” Priglinger-Simader adds.
“They will work with an updated list of illegal websites offering into Germany. And then it’s basically just an update with illegal operators that have come in, [as well as] the whole development of the market. What has been done for 2025 already is an updated list of illegal operators because that of course is very dynamic and has changed over the two or three years,” he says of the report’s methodology.
Despite his dismissal of the GGL’s latest data, Priglinger-Simader admits the drop in channelisation estimates by the regulator is a positive sign it is starting to better understand the market.
Channelisation rate could be used to prevent Interstate Treaty review updates
In June 2024 the regulator suggested the black market only represented around 4% of the overall sector.
But Priglinger-Simader is worried this latest data could be used in the regulator’s favour in the ongoing review of the German Interstate Treaty regulations.
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This is the licensed sector’s only hope for player restrictions like mandatory deposit limits and slot stakes limits to be eased.
He warns the GGL could “use [the data] to say everything is working perfectly fine, and they don’t have to do anything to strengthen the legal [frameworks], and licensed operators could only continue like they did before”.
The review is expected to conclude next year.
Frequently asked questions
Why does DOCV disagree with the GGL’s black market estimate?+–
Simon Priglinger-Simader, vice president of DOCV, says the GGL’s survey-based methodology likely underestimates black market gambling because of ‘non-representative sampling’ and ‘recall bias’.
What is the latest estimated channelisation rate for Germany?+–
The GGL says Germany’s online gambling channelisation rate reached 77% in 2025, while DOCV argues the real figure is closer to 50%.
Why does channelisation rate matter for German regulation?+–
Channelisation is a key measure of whether players are using licensed operators. If the regulator believes channelisation is high, it may be less likely to ease restrictions under the ongoing review of Germany’s Interstate Treaty.
What does GGL stand for?+–
GGL refers to Gemeinsamen Glücksspielbehörde der Länder, a.k.a Joint Gambling Supervisory Authority in Germany. They supervise and regulate cross-border gambling services across the 16 German federal states.
Nicole Macedo
Nicole cut her teeth in local news rooms at home in Gibraltar, and helped to establish the peninsula’s first online-only broadcaster.
