Google Tightens Advertising Rules for German Gambling Market

Google is revising its policy on gambling and games in Germany and will restrict advertising eligibility to operators and affiliates who do not possess a license from the Gemeinsame Glücksspielbehörde der Länder (GGL).

Google to restrict gambling ads from unlicensed operators and affiliates.

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The change, which will take effect later this month, will only allow those licensed by the GGL to apply for advertising certification. Until now, Google permitted companies operating in the German gambling market to advertise to local players without verifying their licensing status. However, starting from 25 September, any company without the necessary license will have its certification applications denied. Moreover, companies currently holding certifications without a GGL license will have their certifications revoked.

While this policy update appears mainly aimed at gambling operators, Google clarified that it also extends to entities offering gambling aggregation services. This includes those who link to multiple gambling operators on their landing pages, indicating that affiliates promoting unlicensed sites will be affected as well.

German Gambling Market Struggles with Illegal Competition

German gambling operators are facing ongoing challenges from the unlicensed market. However, there are conflicting views over the size of the black-market.

In July, the GGL reported that illegal gambling activities accounted for just 4% of the German gambling market in 2023. However, independent estimates provide a stark contrast. For instance, a November 2023 report by the University of Leipzig indicated that unlicensed gambling made up 48.8% of all gambling activities in Germany.

Following the release of the GGL’s annual report, the Deutscher Onlinecasinoverband (DOCV) said that, even by the regulator’s own figures, a black market valued between €400 million to €600 million still represents at least 20% of all gambling activity in the country.

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The Challenges of Combating Illegal Gambling

The GGL does have legal authority to combat illegal gambling, though enforcement measures like IP blocking are currently entangled in legal disputes. This issue is significant as the GGL is expected to produce a report on the effectiveness of the fourth State Treaty on Gambling by 2026. However, with the interim report already delayed, the DOCV anticipates that the final assessment might not be published until 2027 at the earliest.

We expect this [final report] not to come before 2027, which means for some of the measures, they will definitely have to find a way to implement those earlier on, because it will be three more years for the illegal market to thrive without having any consequences.

Simon Priglinger-SimaderDOCV Vice-President

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