Date: 16.04.2025

by Jonasz Papuga

Germany Urged to Take Stronger Action Against Illegal Gambling

The German Sports Betting Association (DSWV) has welcomed the federal government’s pledge to tackle illegal gambling more decisively. However, it argues the coalition agreement remains too vague. To turn political intent into effective policy, the DSWV has presented concrete recommendations.

Strengthening the Legal Market to Counter Illegal Operators

The DSWV believes a strong legal market is the best defense against illegal gambling. Licensed operators must offer products attractive enough to compete with unregulated options. While regulation remains important, overly strict rules can push players toward the black market.

At the same time, licenses and the right to advertise should be seen as valuable tools to build trust and transparency. However, if legal offerings lag too far behind in appeal, consumers will continue turning to unlicensed platforms that operate outside the regulatory framework.

Establishing a Central Prosecutor’s Office for Illegal Gambling

A major obstacle to effective prosecution of illegal gambling in Germany is jurisdictional ambiguity, particularly in cross-border cases. To address this, the DSWV calls for the creation of a nationwide specialist prosecutor’s office with a mandate to investigate and prosecute unlicensed operators, especially those based abroad.

This unit would serve as a central body capable of navigating the international scope of online gambling and closing enforcement gaps between federal and state authorities.

Another pillar of the DSWV’s proposal involves using financial and tax enforcement tools. Authorities are encouraged to adopt a “follow the money” approach, leveraging existing mechanisms in criminal tax law and anti-money laundering to track suspicious financial flows – including those involving cryptocurrencies.

Holding Platforms and Affiliates Accountable

Illegal gambling operators often rely on third-party platforms and affiliate networks for visibility and traffic. The DSWV highlights the role of the Digital Services Act (DSA) in holding these platforms accountable. Under the DSA, platform operators can be required to identify and remove illegal content proactively, which could reduce the reach of unlicensed gambling sites.

The current fragmentation of gambling laws across the European Union presents a barrier to effective enforcement. The DSWV urges the German government to advocate for unified regulatory standards at the EU level, allowing for better coordination and more efficient cross-border action against illegal providers.

The DSWV also places responsibility on Germany’s federal states. It recommends that states use the upcoming review of the Interstate Gambling Treaty to reduce excessive bureaucracy and create a more competitive tax framework. Improving the visibility of legal providers – rather than further limiting it – will help retain players within the regulated ecosystem.