DOCV Says Illegal Sites Took 57% of German Online Gambling Playtime in 2025

Germany’s online casino trade association says unlicensed operators accounted for 57% of the country’s online-gambling playtime in 2025. It is a striking number, but it does not mean that 57% of German online-slot revenue went to illegal sites.

DOCV managing director Julia Lensing gave the figure in a 4 November interview with GlücksWirtschaft. She attributed it to an as-yet unpublished update of research by Leipzig University economist Gunther Schnabl. The earlier study used website-access data to estimate where gambling time was spent; according to Lensing, the updated figure has risen to 57% for 2025.

That puts the industry association sharply at odds with Germany’s regulator, the Gemeinsame Glücksspielbehörde der Länder (GGL). The important detail is that the two sides are not measuring the same thing.

57% of time is not the same as 23% of losses

The GGL study published in March 2026 estimated that unlicensed online gambling represented 22.97% of player losses in 2024, implying a channelisation rate of 77.03% into the regulated market.

Blockchain Research Lab, which carried out the study for the regulator, gives more detail. Its summary of the research says 22.4% of reported stakes and 22.97% of reported losses went to unlicensed providers. It estimated illegal-market gross gaming revenue at €547 million for 2024.

The study was based partly on a survey of 2,000 gamblers and explicitly describes that sample as non-representative. DOCV, meanwhile, is pointing to playtime derived from a different research approach, and the new 2025 update behind its 57% figure has not yet been published.

So the tempting headline comparison — 23% versus 57% — needs a large asterisk. One number is based on losses in 2024; the other is playtime in 2025. A player can spend a long time on one site without generating the same share of stakes or losses, so the two percentages cannot show that the illegal market “jumped” from 23% to 57%.

The measurement dispute now matters for regulation

The disagreement is more than a statistical argument. Channelisation — how much gambling activity stays with licensed operators — is one of the measures used to judge whether Germany’s current regulatory model is working.

The GGL says its 2024 results support the view that the regulated market still accounts for more than three quarters of online gambling when measured through player losses. DOCV argues that traffic and playtime data reveal a much larger unlicensed sector and says the regulator is underestimating it.

For slots in particular, that distinction matters. A claim about time spent on illegal gambling sites is not automatically a claim about slot revenue, stakes or gross gaming revenue. Until the updated Schnabl study is published, the 57% figure is best read as the DOCV’s current playtime estimate rather than a settled measurement of the German online-slot market.

The GGL has said its research will feed into the ongoing evaluation of the Glücksspielstaatsvertrag 2021. The next useful development is therefore not another percentage in isolation, but publication of the underlying 2025 methodology so that the competing estimates can be compared on the same terms.