The Online Gambling Market in Germany, from the beginning of 2021, has undergone a series of changes in its gambling regulations affecting both Advertisers and Affiliate Marketers.
Advertising on the platforms has been restricted to licensed operators only, and the licensing and advertising compliance has been overseen by the Gemeinsame Glücksspielbehörde der Länder (GGL).
Recently, there has been increased enforcement on advertising, including the blocking of sites and the enforcement of advertising fines.
GambleBase research indicates that 76 per cent of affiliate links to online casinos in 2023 were found to be illegally advertising gambling services. This noncompliance demonstrates the regulatory overreach.
New Gambling Regulations in Germany have shaped the advertising policies for Online Gambling in the Country, affecting how Gambling Operators and Affiliate marketers from Online Gambling work. The Regulation on the Interstate Treaty 2021 Legalised Gambling and Established a Licensing Framework for Online Slots, Poker and Other Casino Games.
This Licensing Framework also created a centralised system of control and oversight of the GGL. Affiliate advertisers under the jurisdiction have faced problems, as platforms in digitised advertising have had to change policies and restrict affiliate marketers.
Background on Germany’s changing gambling legal framework
With the 2021 Interstate Treaty on Gambling, online gambling was to be regulated for the first time in Germany. Gambling businesses can offer online sports betting, online poker, online casino games, and virtual slot machines.
The treaty also comes with severe advertising bans; online poker, online slot machines, and online casino games can only be advertised in the evenings from 21:00 to 06:00.
Other advertising restrictions include the ban of misleading advertising, advertising to minors, and performance contracts with affiliates that are based on player deposits or stakes. Also, affiliates must not blur the line between advertising and editorial content.
Despite the advertising restrictions, there have been reports of illegal advertising, especially by offshore operators.
For example, in the newest report by Adlerslots.com, affiliates are still sending traffic to illegal and unlicensed online casinos, continuing the gambling compliance problem in Germany. Adlerslots also reports that affiliates have been asked to confirm the operator’s licensing status before marketing the casino.
Emergence of the Gemeinsame Glücksspielbehörde der Länder (GGL) and what it means for advertising oversight
The GGL’s functions allow it to govern over online gambling activities such as slot machines and poker, as well as other approved games. With a GGL whitelist, it becomes simpler to spot illegal advertisements. The GGL has been successfully enforcing penalties against licensed advertisers who advertise on unregulated gambling affiliate sites.
Given the more precise and focused GGL regulations, the risk for affiliates operating within the grey area has escalated. Unregulated gambling operators can no longer function within a permissive environment.
The risk from unregulated gambling operators has escalated as the GGL and its affiliates are leveraging a more aggressive enforcement style that incorporates restrictions, penalties, and warning systems for both the affiliates and the ad-hosting platforms to reduce the risk.
2024 Google Ads policy update for the German market and its implications
Google’s 2024 restrictions on gambling advertising in Germany are limited to GGL-certified operators. In order to advertise, affiliate marketers must have a direct partnership with a licensed operator, and even direct organic links to unregulated casinos are being monitored more closely.
A 2023 Gambling Market report from GambleBase indicates that seventy-six per cent of German Online Casino affiliate links were non-compliant with legislation.
The recent Google update creates a hard block on the majority of conventional affiliate campaigns. This creates a massive change from how affiliates have used paid search traffic in the past.
Surge in enforcement: fines, advertising bans and payment blocking for non‑compliant operators
The rate of such enforcement action has exploded. The GGL started 231 prohibition proceedings and assessed over 1,700 websites in early 2024, around the time many websites aimed at German users were geo-blocked. Advertisers were also fined when non-compliant affiliate advertising partner websites also promoted, for example, unlicensed gambling offers.
The measure of the scope of the previously unregulated activity has been significant. The GGL also reported monitoring 858 German-language gambling websites in mid-2025, 212 of which hosted the sites, showing that the GGL intervention is effective.
Changes in the market and what affiliates should be aware of
Greater compliance has reduced the scope of activity in the gambling affiliate market. A greater proportion of paid advertising is now concentrated on GGL-licensed operators and is limited.
The others operating in the space remain with significant legal and compliance risk. The non-compliance from the market that is most apparent from the seventy-six per cent metric must be a real concern.
Some affiliates may refocus on Certified Operators and other traffic sources or take on more compliant promotional models.
As for licensed operators, they may enjoy decreased competition from grey-market affiliates and higher consumer trust, but affiliates operating outside the whitelist are likely to encounter severe challenges regarding visibility and profitability.
