The Federal Administrative Court of Germany (BVerwG) has determined that Article 9 of the 2021 State Treaty on Gambling (GlüStV 2021) cannot be invoked to force internet service providers to restrict access to illegal gambling sites. The ruling, released on March 19, 2025, is consistent with an earlier verdict from the Higher Administrative Court of Koblenz and reaffirms current legal restrictions on the implementation of IP blocking against access providers.
This ruling poses a challenge for Germany’s gambling regulator, the Joint Gambling Authority of the Länder (GGL), as it seeks to enforce restrictions on offshore gambling platforms. However, it also means that players can continue to enjoy a variety of online gambling options, including sports betting, lotteries, and the ability to play casino using BTC, without additional barriers.
Since its founding four years ago, the GGL has encountered several legal challenges concerning its power to restrict these sites through internet service providers (ISPs). A comparable case from February 2023, which sought to restrict access to Lottoland, was rejected on similar grounds, strengthening the court’s position against using this enforcement method.
Regardless of the ruling, the GGL has minimized the effect on its ongoing enforcement activities. Since a court ruling in 2022 first classified the practice as illegal, the regulator has not released any orders for IP blocking. Instead, the GGL has shifted its emphasis to enforcement via host providers, a tactic it asserts has proven very effective, albeit resource-heavy.
By focusing on hosting service providers instead of ISPs, the regulator has succeeded in making more than 930 domains unreachable in Germany. About 60 new domains are restricted every month, and when gambling sites reemerge via different providers, the procedure begins anew. Although the process of identifying and targeting these providers is labor-intensive, the GGL insists that this strategy has effectively reduced access to unlicensed gambling sites.
The ruling also brings renewed scrutiny to Germany’s gambling regulation, particularly the country’s relatively low channelization rate, the proportion of players using legal gambling services. Critics within the industry argue that the GGL has presided over a market where many players continue to access offshore gambling sites due to restrictive regulations and limited legal options. However, these figures remain disputed among stakeholders.
In response to the court’s decision, the GGL has been actively working with federal and state-level stakeholders to revise the legal framework for gambling enforcement. The regulator has called for amendments to Germany’s gambling laws to address existing gaps, particularly in relation to IP-blocking measures.
One of the key proposals put forth by the GGL is expanding blocking measures to cover illegal gambling advertising. Under the current framework, the regulator is required to first take action against the gambling provider before pursuing enforcement against ISPs or advertisers. The GGL has suggested waiving this requirement to streamline enforcement procedures, making it comparable to the existing process for payment blocking, which does not require prior action against the gambling operator itself.
The proposed amendments to Germany’s IP-blocking laws fall outside the regular legislative evaluation process of the State Treaty on Gambling. However, the GGL has expressed confidence that these changes will be implemented promptly, emphasizing the need for more effective regulatory tools to combat illegal gambling activities.
Beyond enforcement, the GGL is also pushing for broader improvements to Germany’s gambling regulations. These efforts include initiatives to enhance addiction prevention programs and develop standardized markers of gambling-related harm. In late 2024, the regulator held a joint meeting with state coordinators to discuss these measures, aiming to refine Germany’s approach to responsible gambling.
While the recent court ruling limits the GGL’s ability to use IP blocking against gambling operators, the regulator remains committed to strengthening its enforcement capabilities through alternative means. The ongoing discussions around legislative amendments suggest that Germany’s gambling laws could soon see significant changes, potentially reshaping the regulatory landscape in the coming years.
As the debate continues, industry stakeholders and policymakers will be closely monitoring the effectiveness of existing regulatory tools in maintaining a fair and secure gambling market. With unlicensed operators continuously adapting to enforcement measures, regulators face an ongoing challenge in striking the right balance between effective oversight and ensuring a competitive, legal gambling industry. The success of future legislative amendments will depend on how well they address these challenges while maintaining consumer protection and market integrity.
For now, the GGL continues its battle against unlicensed gambling operators through host provider enforcement and other indirect measures. However, the regulator’s call for expanded legal powers signals a growing urgency to modernize Germany’s approach to gambling enforcement, ensuring that it remains effective in an evolving digital landscape.