Germany’s GlüStV 2021 Review Puts Market-Channelization Claims Under Pressure Ahead of 2026

Germany is heading into a review of the GlüStV 2021 interstate gambling treaty by the end of 2026, and the main argument is no longer theoretical: how much of the market is staying legal, and how much is drifting offshore. For licensed operators and the PSPs that serve them, the answer matters because it shapes deposit limits, product restrictions, tax pressure, and whether regulated traffic can actually compete with the offshore alternative.

1. The review is focused on the Kanalisierungsquote — the channelization rate, or the share of players that remain in the legally regulated market instead of moving to unregulated offshore sites. That metric is now the political and commercial fault line around GlüStV 2021.
2. The GGL (Gemeinsame Glücksspielbehörde der Länder) said for years that the legal market captured the vast majority of players. More recently, it admitted that the black market accounts for at least 25% of the total market for online sports betting, virtual slots, and online poker.
3. External estimates are harsher. A late-2025 study by the Handelsblatt Research Institute concluded that the online black market already exceeds 50% of total market share. In online casinos and virtual slots — the verticals hit hardest by strict deposit caps and spin-speed restrictions — the illegal market allegedly controls 70% to 80% of activity.
4. H2 Gambling Capital puts Germany’s channelization rate at just 36%, which implies that a majority of users are choosing illegal sites. For PSPs, that is the practical question behind the regulatory debate: if regulated product is too constrained, traffic does not disappear, it reallocates.
5. Industry groups say the pressure is getting worse. According to data presented in 2026 by the DSWV (German Sports Betting Association), illegal operator revenue rose 17% between 2023 and 2024, while the number of accessible illegal betting websites increased 36% over the same period.

One more number in the background: the legal online market’s GGR per capita averages €98 across Europe, while Germany’s regulated market is being described as operating under a 5.3% tax on deposits. For anyone building payments around Germany, that combination is the whole story in miniature: tight rules on the front end, and a market that may be doing its best to route around them.