In mid-April, the party leaders of the CDU, CSU and SPD presented their plans for a joint government. The coalition agreement in question also contains a specific passage on illegal gambling, in which an improvement in the fight against such offers is announced. From the industry's point of view, this is "great progress" and an "important signal". Associations are now calling for more clarity and are campaigning for changes. In fact, the stipulation increases the chances that something will change noticeably - also for players.

It's just a single sentence: scattered in line 2901 of a paper over 140 pages long. And yet it is attracting attention - at least among those who are professionally or passionately involved in gambling. The CDU, CSU and SPD agreed on a coalition agreement in mid-April. It literally states: "Together with the federal states, we will improve the fight against illegal gambling."

What may seem like a typical political phrase at first glance could actually mark a turning point. For the first time, illegal gambling is explicitly given space in a coalition agreement. The industry is certainly not taking this step lightly. The German Sports Betting Association (DSWV) speaks of an "important signal". For the German Online Casino Association (DOCV), it is even a "major step forward". For the Deutsche Automatenwirtschaft e. V. (DAW), one thing is certain: "This step was urgently needed."

The need for action is shown not least by current data analyses from H2 Gambling Capital: unusual anomalies in German online gambling indicate (repeatedly) that the black market is far larger than official estimates have previously suggested. A development that could pose a real threat not only to licensed providers, but also to players.

But what does the new regulation really mean? How realistic is it that real measures will follow? We have taken a closer look at the reactions from the industry and the possible (positive) effects for players.

What the industry is now demanding from politicians

No sooner had the new coalition agreement been published than the most important representatives of the industry had their say. The German Online Casino Association, the German Gaming Machine Industry Association and the German Sports Betting Association welcomed the political commitment to combating illegal gambling - and immediately followed up with concrete proposals. One thing was made clear: the growing black market can in no way be curbed with euphonious formulations alone.

DOCV

"This step was long overdue," emphasizes DOCV President Dirk Quermann and underlines: "Strengthening the legal offer through timely regulatory adjustments is the most effective way to turn these words into action."

The magic word is channeling - players should be deliberately guided back into the legal market. Because there, and only there, clear rules and effective player protection apply. The association's press release therefore states unequivocally:

"We must lead players back out of the unprotected black market and back into the legal market, because that is the only place where player protection can be guaranteed. This can only work if we strengthen legal gaming," emphasizes Quermann. "The DOCV is always available for dialog. Viable solutions can only be developed and advanced in a joint exchange between industry, politics, research and administration."

There will soon be an opportunity for implementation: the evaluation of the Interstate Gambling Treaty 2021 is imminent - and with it the chance to revise existing regulations in a targeted manner. From the DOCV's perspective, this includes, among other things

DAW

In the press statement from the German Gaming Industry Association (DAW), its CEO Georg Stecker speaks out:

"We expressly welcome the fact that the new German government has named the fight against the illegal gambling market as a concrete goal." Stecker also emphasizes: "This step was urgently needed." He continues: "Now it is important to strengthen the legal providers with smart regulation and thus combat the evil of illegality at its root. Our legal supply is safe. Now it must once again meet consumer demand and be sufficiently available."

DSWV

The DSWV is also actively involved in the debate in a press release - with a whole list of proposals on how enforcement against illegal offers can be strengthened. Once again, the most important point is that strong legal competition is seen as the best answer to the charms of the black market. This requires more than just licenses - it needs attractive products, fewer bureaucratic hurdles and clear responsibilities.

  • The association is particularly calling for the establishment of a nationwide public prosecutor's office that can take targeted action against illegal gambling - especially on the internet. This is because many proceedings currently fail due to unclear responsibilities or the cross-border structure of typical black market providers. In this context, the GGL recently called for Section 284 of the German Criminal Code to be extended to include online gambling.
  • It also proposed a "follow the money" approach: money flows - including in cryptocurrencies - should be consistently tracked, ideally with the involvement of the tax authorities and financial supervisory authorities. The association also believes that the big internet players such as Google have a duty. According to the DSWV, advertising and affiliate networks should take more active action against illegal content. The Digital Services Act (DSA) would offer new legal possibilities for this.
  • The DSWV also advocates for European harmonization of gambling regulation - because the current patchwork makes consistent enforcement of national rules almost impossible.

For the federal states, all of this also means: act now. The evaluation of the Interstate Treaty on Gambling should be used to reduce bureaucracy, modernize the tax framework and stop further restricting the visibility of legal providers.

The gambling passage in the coalition agreement therefore increases the chance of real change and more freedom for players

It is a novelty - and a glimmer of hope for many: with the new coalition agreement, the fight against illegal gambling has finally reached federal level. This is remarkable, as up to now it has mainly been regional initiatives that have caused movement. Be it the demand of the FDP in North Rhine-Westphalia for faster approval procedures for online casinos(more on this here), the possible advertising ban for betting providers in Werder, which Bremen's Senator of the Interior Ulrich Mäurer brought into play(more on this) or the proposal from Schleswig-Holstein to make providers of online table games contribute to any therapy costs following approval there(more on this).

Up to now, all of these initiatives have been in the area of conflict between individual federal states - often with a very restrictive character. Now, however, for the first time, a federal political will is emerging that could be of strategic importance, not just symbolic. Because if the CDU, CSU and SPD commit to actively combating illegal gambling at federal level, the political pressure to take concrete measures will also increase.
Munich-based gambling law expert Wulf Hambach puts it in a nutshell in the international trade press: "If the federal government realizes that the black market is growing, that would be a political failure - and that is something that Berlin wants to avoid at all costs."

For Hambach, the gambling passage in the coalition agreement is therefore more than just lip service - it is a first step towards real reform. The advantage of the federal level? It allows a more rational view of the industry. While individual states - especially SPD-led states such as Bremen - repeatedly insist on tighter restrictions, the CDU, for example, is much more objective when it comes to gambling issues.

"I am confident that new, more balanced approaches will be found with the upcoming reform of the State Treaty on Gambling," said Hambach.

This also includes a critical look at existing regulations, which industry members and players have long considered unrealistic. Such adjustments could help to make the legal market more competitive - a key element in bringing players back from the black market. The opportunity for change seems more tangible than ever.

Conclusion

The coalition agreement between the CDU, CSU and SPD contains more than just a symbolic gesture - it sends out a clear signal: The federal government is taking the fight against illegal gambling seriously and is explicitly committing to regulation at national level for the first time. Although this alone does not change anything, it lays the foundation for real change.

What matters now is the political will - and the willingness of all those involved to take responsibility. Only if politicians, the industry and the authorities pull together can a market be created that is both safe and attractive. One that protects players and puts illegal providers in their place.

The federal government's entry into gambling regulation could be exactly what many have been hoping for: a game changer. After all, the higher the political level, the less likely it is that the issue will disappear into a drawer again. Nothing has been decided yet, but the path has been paved. The inclusion of the topic on the national agenda is forcing action - unlike at state level, where blockades have often prevailed instead of movement.

The hope remains that the frequently criticized "standstill" in the German gambling market will finally come to an end - and that the coalition agreement will become more than just a political promise.

Source of the image: https://pixabay.com/photos/man-sign-paper-write-document-5710164/

Central text sources: https://casinoverband.de/blog/klares-bekenntnis-gegen-illegales-glucksspiel-docv-begrusst-neuen-koalitionsvertrag, https://www.dswv.de/dswv-begrusst-koalitionsvertrag-jetzt-konkrete-massnahmen-gegen-illegales-glucksspiel-umsetzen/, https://www.automatenwirtschaft.de/koalitionsvertrag-bekennt-sich-zur-bekaempfung-des-illegalen-gluecksspiels-automatenwirtschaft-begruesst-zielsetzung-und-fordert-ganzheitlichen-ansatz/, https://igamingbusiness.com/offshore-gaming/germany-new-government-illegal-gambling/, https://www.spd.de/fileadmin/Dokumente/Koalitionsvertrag2025_bf.pdf

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