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FEATURE
relatively underdeveloped market – at least in terms of the regulated sphere .
Compared to its more mature cousin , the United Kingdom , where the online gaming market is worth an estimated € 12.05bn , the legal online betting and gaming market in Germany turned over an estimated € 4.8bn in 2023 , based on industry tax revenues .
Most surprisingly , this is in a jurisdiction with a population of 84 million , compared to the UK ’ s 65 million . In the view of operators , Germany is still a market plagued by challenges – but that nonetheless offers opportunities . The current regulatory framework has been described by the German Sports Betting Association ( DSWV ) as “ the most restrictive in the world ”, and the battle for a fairer and more cooperative entity is ongoing .
1,380
Number of illegal operators targeting German players ( source : Yield Sec )
€ 4.8bn
Estimated value of German market , based on federal gaming taxes
REGULATORY CHALLENGES
Under the current licensing scheme , sports betting and online casino operators apply for a licence from the GGL , which allows them to operate legally within any state in Germany .
According to German gaming law firm Hambach & Hambach , this process has been relatively smooth and transparent for its clients , but the stringent rules on everything from advertising to operating slots still presents difficulties for licence-holders .
“ The licence conditions are very harsh ,” explains Wulf Hambach , founding partner at Hambach & Hambach . “ You have a catalogue of licence conditions that is pages long and dozens of regulations just on advertising and , in some cases , you have licence conditions that aren ’ t part of the law but have been added later .”
In five areas in particular , operators are deeply unsatisfied with the state of the current regulation .
RESTRICTIVE ADVERTISING MEASURES
Summarising Germany ’ s advertising framework , Luka Andric , managing director of the DSWV , describes it as “ extremely strict ”.
Wulf Hambach , Hambach & Hambach
“ It ’ s probably one of the strictest around unless you take a monopoly system or somewhere you have a complete ban on advertising ,” he says .
The rules that operators must navigate include a blackout on online and TV advertising between 9pm and 6am , restrictions on displaying sports clips in advertising and a ban on working with sports personalities and other influencers .
According to Andric , there are even calls for the restrictions to be tightened up further .
“ Some politicians are now starting a debate about sports betting advertising , which is the most effective tool that legal operators have to draw attention to the legal products ,” he says .
64 • ISSUE 135 • ICE LONDON 2024