Malta among EU states cited in Germany’s black market gambling report

Malta has been mentioned in Germany’s latest crackdown on unlicensed gambling operators, raising fresh scrutiny on its role within the European online gaming landscape.

According to the 2024 report by Germany’s gambling regulator, Gemeinsame Glücksspielbehörde der Länder (GGL), of the 212 operators identified as illegally targeting German players, 19 are based in EU member states – with Malta being the only EU country singled out in the accompanying report footnotes. Most other operators were from non-EU jurisdictions, predominantly Curaçao.

The report highlights that these 212 operators were behind 858 German-language gambling websites, a market the regulator estimates to generate between €500 million and €600 million in annual gross gaming revenue. The vast majority of these websites offer online slot games and casino products.

Malta, home to one of Europe’s largest iGaming sectors, was cited in the report’s data table, which specifies “EU-based operators including Malta” under the list of unauthorised providers. This detail – though seemingly small – may reignite wider debates around Malta’s gaming supervision, particularly in relation to companies targeting foreign markets without local authorisation.

The German regulator’s findings have already drawn sharp criticism from the industry. Christian Heins, Director of iGaming at Tipico, publicly disputed the GGL’s market estimates on LinkedIn, arguing that the illegal market is likely worth at least €1.5 to €2 billion – far above the regulator’s €500-€600 million assessment.

Mr Heins based his estimate on online traffic data, which reportedly shows that black-market sites receive up to 50 per cent more visitors than licensed ones. He also questioned the regulator’s reliance on measures like geo-blocking and payment-blocking, suggesting their impact on curbing illegal gambling has been overstated.

Regulatory pressures mount

The GGL, however, remains confident in its approach, citing stronger enforcement through prohibition orders, digital services restrictions, and new advertising rules on platforms like Google. Since late September 2024, only licensed operators are permitted to advertise gambling services via Google Ads in Germany.

Despite this, the GGL admits that combating illegal gambling remains a long-term challenge, requiring persistent cross-border cooperation – especially with jurisdictions like Malta, often home to operators serving multiple markets under their EU licenses.

Growing European focus

Malta’s mention in the German report may not sit well with its regulators, particularly as the country has been actively defending its position amid increased EU-wide regulatory scrutiny. Notably, Malta’s controversial “Bill 55” – which aims to shield its licensed operators from foreign legal actions – also faced European Commission concerns last year.

In June, The Malta Gaming Authority clarified that “Article 56A does not impose a blanket ban on enforcing European judgments against Maltese-licensed gaming companies, nor does it shield them from legal action in other EU courts.” It stressed that the provision reflects Malta’s existing public policy under EU law, particularly the ordre public exception contained in the Brussels I Recast Regulation.

It added that Malta’s licence model allows companies to offer services across borders “provided they have a justifiable legal basis for doing so and that they continue to comply with the Maltese regulatory framework.”

The Maltese Government echoed this view, stating: “The Government reiterates that Article 56A of the Gaming Act does not establish new or separate grounds for refusing recognition or enforcement of judgments beyond those set out in Regulation (EU) 1215/2012 (Brussels I Recast). Rather, it codifies into law Malta’s long-standing public policy on online gaming matters.”

The Government confirmed it will formally respond to the Commission’s letter within the stipulated two-month timeframe and reaffirmed its commitment to open dialogue, noting: “Malta remains fully committed to maintaining a constructive dialogue with the European Commission.”

As the European gambling landscape becomes increasingly fragmented, Malta’s gaming community finds itself once again at the centre of a high-stakes regulatory debate.