At the end of September 2024, Google will change its policy on gambling and gaming advertising in Germany. According to the new rules, only operators and affiliates licensed by the Gemeinsame Glücksspielbehörde der Länder (GGL) will be able to apply for certification to place ads.
Previously, Google allowed companies operating in the German gambling market to place ads without checking whether they had a license. However, from September 25, certification applications from unlicensed operators will be rejected. Moreover, all previously issued certificates for such companies will be revoked.
While the changes primarily affect operators, Google has clarified that they also apply to those providing aggregation services, such as links to multiple offers from different operators on one page. This means that affiliates promoting unlicensed sites will also be subject to the new rules.
The gambling black market in Germany: an ongoing battle
These changes come as German gambling operators are in a serious battle with unlicensed competitors. Despite claims that the illegal market is small, independent studies show the opposite.
In July 2023, GGL published an interim report stating that illegal gambling accounts for only 4% of the total market. However, this figure differs greatly from independent estimates. A November 2023 report from the University of Leipzig stated that unlicensed gambling accounts for 48.8% of all activity on the German market.
Following the publication of the GGL’s annual report, the Deutscher Onlinecasinoverband (DOCV) pointed out that even according to the regulator, the black market is estimated to be worth between 400 and 600 million euros, which is at least 20% of the total gambling volume.
The regulator has the power to combat illegal activity, but measures such as blocking IP addresses face legal hurdles. This is especially relevant ahead of the GGL’s report on the effectiveness of the fourth State Treaty on Gambling Regulation, which is scheduled to be published in 2026. However, given the delays in the interim report, the DOCV does not expect the final assessment to be available until 2027.
“We assume that the final report will not be available until 2027, which means that for some measures, a way will have to be found to implement them earlier, otherwise the black market will continue to flourish for another three years without consequences,” DOCV Vice President Simon Pringlinger-Simader told iGB in July.