Address by Ms. Nadja Wierzejewski, Head of enforcement, GGL, at the 2026 Gaming in Germany Breakfast @ICE

Unofficial courtesy translation by Gaming in Germany

Welcome to this Gaming in Germany Breakfast in a year full of changes.

The first thing I would like to say is that I won't torture you with my poor English. Instead, I will address you in German.

Second, I won't bore you with figures about hearings and prohibition orders. Instead, I would like to give you a little insight into our current approach. So let's directly address the question that is in everyone's mind: What is the GGL doing to combat the black market? And even more so, what is the GGL doing to successfully combat the illegal market?

The aforementioned hearings and prohibition orders are certainly one component of this. Our goal is to steer online gambling in an orderly and monitored direction and to strengthen player protection. As was already stated at the Gaming in Germany Conference last year in Berlin: "Let's reclaim the market.”

When the GlūStV 2021 was first drafted, it was already clear that the classic instruments of German administrative law, which were developed for land-based, domestic circumstances, would not work on the transnational world wide web. Therefore, in addition to the general, gambling-related clauses, payment and IP blocking were also explicitly enshrined in the treaty.

How have these instruments proven themselves in practice?

We have largely succeeded, through a cooperative approach, in convincing payment service providers not to work with illegal providers. Only in rare cases proved it necessary to apply a little pressure. Although some of the major payment service providers can still be found offering their services on illegal sites, their logos do not lead the user to the expected application. Instead, users are passed from one service provider to another.

While it must be clear that this does not automatically lead to the disappearance of the offer, it does make it more expensive, which thus reduces profits, as new, sometimes dubious PSPs have to be partnered with again and again. Since these PSPs are often unknown to the player, the dropout rate also increases. All in all, this reduces the profitability of the illegal offer.

In the case of IP blocking, it has become apparent that the provisions of the GlüStV 2021 do not meet the requirements of the courts. For this reason, a legislative process has been initiated to bring about an amendment to the GlüStv 2021 in all 16 states. The notification period and related consultations have already been completed.

On the current legal basis, it has, however, already been possible to take action, together wuth rhe DSA, against the hosting providers of illegal websites. Of course, illegal operators will look for a new hosting provider, and it would be naive to believe that the site would disappear permanently after a one-time blackout.

We keep, however, tracking these websites drive them, so to speak, before us. This means that the site has to move constantly. Not only does this tie up capacity, it also costs money. In addition, hosting providers are becoming aware of the fact that not every offer is permitted everywhere, but that it may also be a prohibited, illegal offer.

In general, the importance of educating necessary service providers should not be underestimated. Especially in the area of advertising for illegal gambling, education is a powerful weapon that limits the advertising opportunities of illegal operators.

Furthermore, action is not only being taken against the advertisers themselves, but also against search engines and social media platforms. For instance, a major search engine provider was persuaded to remove both paid and organic search results for illegal operators from its search results.

Initial, promising results have also been achieved in the area of influencer advertising.

All this, of course, in addition to the action that is always taken against the advertiser itself.

As a further development of this approach, we will combine our various approaches and take simultaneous action against illegal operators with a large market share. This means that both the classic injunction proceedings and payment and IP blocking will be carried out at the same time.

In addition, action will be taken against advertisers and affiliated service providers. As a result, illegal operators will have to reserve more capacity to respond to the resulting complications.

Furthermore, the GGL will not only take action against the aforementioned actors, but will also focus on all identified contributors to the value chain.

Our initial measures against these participants in the value chain have shown that illegal operators deliberately mislead their service providers, such as aggregators, about their status when signing contracts. Non-German European licenses and even non-European licenses are often presented as licenses valid in Germany

However, since the gambling market in the EU is not harmonized, their claim that such licenses are valid is simply not true. It is completely false. As you all know, in the individual EU member states, legal gambling requires a license from the respective state.

Here, service providers are deliberately deceived so that illegal operators may in create an attractive and high-quality offering.

Still, this doesn't mean that these service providers don't come under our scrutiny. Everyone in the value chain is a potential target of a German injunction. This can cause unrest, and not only for listed companies. A prohibition order in Germany can also have a negative impact on licensing procedures in other European countries.

Hete, I would also like to note that I find it regrettable that licensed operators are not utilizing their opportunities to restrict the black market, which, naturally, should be in their interest. Tipico's Trusted Partner campaign is a welcome, but lone exception.

After all, I would be very surprised if it were not common knowledge in the industry who has contractual relationships with whom. This raises the question of whether a blind eye is being turned when one's own aggregator also works for illegal operators.

From my time as a supervisor in the land-based sector, I know that civil law proceedings and clearly communicating to the outside world that you are distancing yourself from service providers that also serve the black market are both effective.

Because the regulatory authority does not yet have the active support of criminal law enforcement, due to the cross-border nature of the issue of illegal gambling, support from the industry is both necessary and desirable.

Of course, this does not release us from our obligation to do everything possible to combat the illegal market. The GGL is therefore working tirelessly to ensure that the German Criminal Code is amended so that providers of illegal online gambling can and will also be prosecuted criminally. Here, too, constant pressure from all market players is needed to make this endeavor a success.

All actors in the online market - be they operators, service providers, addiction support organizations, legislators, or regulators - agree that the aim is to create a market with a high degree of market channelization that is safe for players. However, cooperation is necessary to achieve this goal. Only if pressure is exerted on illegal operators from all sides, by isolating them and exposing them as lawbreakers, can we achieve this goal.