Germany’s Joint Gambling Authority of the States (GGL) wants the power to change its own enforcement measures without waiting years for the 16 federal states to renegotiate the Interstate Treaty on Gambling 2021 (GlüStV 2021). GGL board member Ronald Benter said the current rules leave the regulator too slow to keep up with unlicensed online operators.
Benter set out the position in an interview with the Mitteldeutsche Zeitung, published as the GlüStV 2021 goes through its formal evaluation. His argument is that the treaty fixes too much in detail, so even changes the GGL and the states agree on can take several years to reach the statute book.
“The illegal market is very dynamic. That’s why we as an authority need to be faster,” Benter said.
A shorter route for new measures
Under the GlüStV 2021, the GGL enforces a framework written and amended by the states. Any change to the treaty requires agreement among all 16 of them, followed by ratification in each state parliament. Benter said that process cannot respond quickly enough to new technology, new payment routes and shifts in how unlicensed operators structure their businesses.
His proposal is to give the GGL more discretion to decide on new enforcement measures itself, with the authority’s Administrative Board (Verwaltungsrat) overseeing those decisions. The states are represented on that board, so they would keep a say over what the regulator does, through a shorter approval process than a treaty amendment.
“But ultimately, we have the expertise and should therefore be able to react more quickly to developments and decide on new measures,” Benter said.
He wants the change considered as part of the ongoing treaty evaluation. The GGL has not published a draft text, and any shift in its powers would still need the states to sign off on a revised treaty.
The current enforcement toolkit
The GGL, based in Halle (Saale), took over full responsibility for online gambling supervision in Germany at the start of 2023. Its tools against the black market are administrative: prohibition orders against unlicensed operators, payment blocking through banks and payment service providers, IP and network blocking, action against illegal advertising, and referrals to public prosecutors.
Benter warned that slow rule changes let illegal operators adapt faster than the authorities pursuing them, which in turn puts pressure on the licensed market. German licensees have long complained that tight rules on stakes, deposit limits and game design push players toward offshore sites that ignore them. Trade bodies also dispute the GGL’s own figures on the size of the black market, with the German Online Casino Association (DOCV) citing independent data that puts the illegal share far above the regulator’s estimate.
Pressure on prosecutors
The second part of Benter’s intervention was aimed at the criminal justice system. The GGL wants public prosecutors to open more proceedings against individuals based outside Germany who are suspected of offering gambling to German consumers without a licence.
“This is almost never done so far, but it could increase deterrence,” Benter said.
Many unlicensed brands targeting Germany are run by companies registered abroad, which limits what administrative orders from Halle can achieve. Criminal proceedings against the people behind those companies would carry a personal risk that blocking orders do not.
Frankfurt case shows scale of the black market
Benter’s comments follow one of the largest illegal gambling investigations Germany has seen. On 9 September 2026, more than 100 officers searched 11 residential and commercial properties in Frankfurt and the wider Rhine-Main region after an investigation that had run covertly for more than three years.
The operation involved the Frankfurt Public Prosecutor’s Office, Frankfurt tax investigators, the North Rhine-Westphalia State Office for Combating Financial Crime and Frankfurt police. Five people are suspected of commercially and collectively operating unlicensed online gambling platforms since at least July 2021. One principal suspect was arrested under a warrant.
According to prosecutors, the platforms took around €5.86 billion in player stakes between July 2021 and the end of 2023. The suspects are also accused of underpaying gambling taxes, with the estimated tax loss for 2024 alone put at €77.6 million. Authorities executed an asset-freezing order of around €82 million, seized several high-value vehicles and froze multiple bank accounts.
The GGL welcomed the investigation and said it supports prosecutors by sharing intelligence from its payment-blocking cases, network restrictions, advertising enforcement and reviews of operators’ technical and corporate structures. The suspects have not been convicted, and the investigation is ongoing.
What happens next
Whether the GGL gets the powers it wants depends on the states. The GlüStV 2021 evaluation is the vehicle for any change, and the states will have to decide how much control over enforcement detail they are willing to hand to the Administrative Board. On the criminal side, the Frankfurt case will test how far German prosecutors can follow unlicensed revenue through to the individuals behind it, and whether that becomes a model for cases involving operators based abroad.
Source: Gemeinsame Glücksspielbehörde der Länder (GGL)
