Tax probe of Platincasino reopens debate on Germany’s online black market

By Miguel Sandoval, Regulatory correspondent.

The Frankfurt public prosecutor attributes a presumed tax loss of €77.6 million to Platincasino in 2024, a sum that represents 36.3% of the €213.5 million paid in taxes by the legal market for virtual slot games that year. The direct tax‑to‑tax comparison challenges official estimates of the size of the online black market in Germany.

Direct tax comparison

The Frankfurt prosecutor’s office calculates that Platincasino generated tax evasion of €77.6 million in fiscal year 2024. The entire legal market for virtual slot games declared and paid roughly €213.5 million in tax in 2024. Comparing these amounts within the same tax category and period, the Platincasino case equals 36.3% of the tax collected from the legal market.

Analysts on the case note this is a comparison “tax against tax”, which avoids the common distortions that occur when wagering or gross gaming revenue (GGR) figures are juxtaposed. The report says differences in return‑to‑player structures between licensed and unlicensed operators make GGR a less reliable indicator of illicit market scale.

"Comparing tax obligations provides a clearer benchmark to assess the size of the illicit market," the fiscal analysis summary states.

Contrast with official figures

The Joint Gambling Authority of the German States (GGL) published a study in March 2026 estimating that unlicensed operators account for approximately 23% of GGR, leaving the regulated market with about 77%. However, the prosecutor’s investigation into Platincasino raises questions about the representativeness of that 23% when a single illicit operation can equal more than one third of the legal segment’s tax take.

In 2024 the GGL identified 212 illegal operators running 858 German‑language websites, and based many conclusions on modelled estimates because unauthorized entities are not subject to mandatory reporting. Investigators in the Platincasino case demand that the prosecutor’s findings be incorporated into the GGL’s methodological reviews.

Independent studies and other estimates

Independent research produces substantially higher figures than the official estimate. The Handelsblatt Research Institute estimates the illegal share of online gambling in Germany exceeds 50%, and that for online casinos and virtual slot games the portion could be between 70% and 80%. Professor Gunther Schnabl, in a study on time spent on gambling sites, concludes the black‑market share is around 50%.

These figures broaden the debate over actual channeling of demand to regulated offers and the effectiveness of supervision.

Review of the regulatory framework: GlüStV and the five‑year evaluation

The five‑year evaluation of the State Treaty on Gaming (GlüStV) required by Article 32 must assess whether the treaty protects consumers and channels demand to state‑regulated offers. Sector stakeholders say law‑enforcement discoveries, such as the Platincasino investigation, should be integrated into the evaluation to accurately estimate illicit market penetration.

The evaluation process will decide which data and methodologies are admissible to measure market channeling and the effectiveness of player‑protection measures. Some participants request that direct tax comparisons — like the €77.6 million versus €213.5 million example — be added to the official analytical toolkit.

Implications for control and measurement

The Platincasino case provides a concrete empirical data point to test modelled estimates. If the €77.6 million figure proves representative of other illicit operations, the true size of the black market would be far larger than the 23% of GGR estimated by the GGL. Regulators and tax authorities may consider incorporating direct fiscal analysis and criminal investigation results into their metrics; payment and tax data can offer complementary evidence for measurement.

Regulators and fiscal authorities will need to decide whether to include direct tax analyses, criminal investigation outcomes and independent studies — such as those by the Handelsblatt Research Institute and Gunther Schnabl — in the GlüStV evaluation metrics. Meanwhile, the tax‑against‑tax comparison for 2024 leaves open how much online gambling consumption in Germany is truly channelled through the regulated market.