At the heart of Europe, Germany is fighting a battle it seems destined to lose. The enemy? Illegal gambling. But on closer inspection, it’s not criminal gangs holding the strongest cards -it’s bureaucracy and short-sighted politics, unable to distinguish between regulation and repression.
According to alarming data released by Deutsche Automatenwirtschaft (DAW), the leading association representing the amusement and gaming machine industry, one in three machines operating in the country is already illegal. And if nothing changes, the projection is even more dismal: soon, one in two will fall outside the law.
It’s a stark equation: the more legal gaming is squeezed, the more the black market thrives. This was made all the more evident during a police raid on 10 July in a town near the French border, which resulted in the seizure of numerous unauthorised machines from gaming halls suspected of illicit activity. While no arrests were made, authorities confirmed serious concerns about tax evasion and breaches of gambling laws. A stark reflection of a nation losing grip on its gaming sector.
The 2021 Treaty: When rigour backfires
At the root of the problem lies the Glücksspielstaatsvertrag, the Interstate Treaty on Gambling that came into effect in 2021. A reform intended to regulate and protect – but one that has ended up choking the legal sector. One of its most controversial provisions limits each public venue to a maximum of two gaming machines. In practice, this has had the opposite effect of what lawmakers hoped.
Georg Stecker, spokesperson for DAW, makes the point plainly: “Gamblers haven’t disappeared. They’ve just moved into unregulated circuits, where there are no checks, no limits, and no protections.”
Exacerbating matters is the failure to update the maximum stake per play. Amidst rampant inflation and rising operational costs, keeping bet limits static has pushed legal operators to the brink of unprofitability – while the illegal sector flourishes without constraint.
The State’s response: enforcement without reform
Germany’s Ministry of the Interior praised the 10 July crackdown as a “clear signal against illegality.” But signals alone are not enough. What’s needed is strategy – specifically, regulatory reform that restores legality as a viable, competitive alternative.
Because that’s the crux of the matter: competition. At present, legal operators are unable to compete. They are shackled by restrictions on machine numbers, burdened by tax pressure, and paralysed by a lack of regulatory flexibility. Meanwhile, the black market is booming – free of age checks, tax obligations, or safety standards. It’s a digital and physical wild west, stretching from urban outskirts to city centres.
A sector under siege: numbers and demands
Germany’s legal gaming and amusement machine sector is no fringe industry. It is an industrial powerhouse: over 2,100 businesses, 56,000 employees, and an annual turnover of around €5 billion. Today, this sector is crying out for reform – calling for a review of machine quotas, an inflation-indexed adjustment to stake limits, and the reintroduction of a three-machine-per-venue standard.
This is not about profit maximisation at any cost. It’s about offering a safe, regulated, and accessible alternative to illegal gambling. As Stecker highlights, “Without a sufficient, sustainable, and competitive legal offering, there’s no way to seriously combat illegal gambling”.
Learning from Italy (and others)
Germany is not the first European nation to suffer the unintended consequences of over-regulation. Italy, with its restrictions on slot machines in bars and tobacconists, saw a surge in unlicensed online gambling. France opted instead for strict but competitive concession models, while Spain is currently re-evaluating its gaming tax structure to avoid driving operators underground.
What’s needed is a coordinated European approach – based on balance, transparency, and realism. The fight against illegal gambling won’t be won through raids alone, but through policies that keep players within a regulated, secure system.
Time is running out
The gambling market doesn’t tolerate a vacuum. Where the state withdraws, illegality steps in. Where the law constricts, the black market expands. Germany must urgently listen to industry voices, revisit its legislation, and deploy a reform strategy that supports legal operators and punishes true offenders – not with slogans, but with fair, effective, and forward-looking rules.
Because the real stakes aren’t just economic. They’re legal. They concern the protection of citizens. The survival of an entire industry. And perhaps, the credibility of state governance itself.
This article was first published in Italian on 28 July 2025.



