Black Market Instead of Player Protection: An Alarming Analysis of Google Rankings

Intro

The German sports betting market finds itself in a paradoxical situation. While regulatory authorities have been striving for strict controls and player protection since introducing the new Interstate Treaty on Gambling in 2021, digital reality paints a very different picture. A recent analysis of Google search results reveals a troubling development: comparison portals promoting unlicensed betting providers occupy prominent positions in search engines.

The regulated sports betting market in Germany is subject to strict regulations. Betting operators wanting to operate in Germany legally must obtain a license from the Joint Gambling Authority of the States (GGL). This license comes with stringent requirements, including a monthly deposit limit of €1,000, a panic button for players, no simultaneous games, and a comprehensive self-exclusion system. These measures are designed to protect players from addiction and financial losses.

However, reality tells a different story. Numerous operators circumvent these regulations by operating without a German license, instead relying on licenses from Malta, Curaçao, or other jurisdictions. These operators often advertise higher odds, unlimited deposits, and fewer restrictions—precisely the factors from which German legislators aim to protect their citizens. The most alarming aspect: these unlicensed operators are not hidden in the dark corners of the internet. Instead, they are prominently displayed on the first page of Google, often through comparison portals.

This development raises questions not only about the effectiveness of German gambling regulations but also about the role and responsibility of established search engines like Google, which grant prominent positions to comparison portals that list unlicensed betting providers. A closer examination of these interconnections reveals a system that systematically undermines player protection.

The Legal Situation in Germany

The legal framework for sports betting in Germany was fundamentally restructured with the Interstate Treaty on Gambling 2021 (GlüStV 2021). After years of legal gray areas, the legislator created a clear framework for the digital sports betting market for the first time. The goal: a regulated offering that protects players while channeling natural gambling impulses into controlled paths.

The requirements of the Interstate Treaty are deliberately stringent. Betting providers must:

• Implement a monthly deposit limit of €1,000 per player
• Offer a “panic button” for immediate self-exclusion
• Participate in the overarching OASIS self-exclusion system
• Set up an automatic system to detect problematic gambling behavior
• Significantly restrict live betting
• Technically prevent simultaneous betting with multiple providers
• Disallow parallel games with the same provider

The German license, issued by the Joint Gambling Authority of the States (GGL), is more than just a formal document. It serves as proof that a betting provider meets these strict requirements and is subject to continuous monitoring by German authorities. Licensed operators must also provide a security deposit in the millions and make significant technical investments to meet the requirements.

For unlicensed providers, the legislator has imposed severe consequences, ranging from cease-and-desist orders and heavy fines to criminal prosecution. Collaborating with such providers—through advertising or affiliate marketing—is also illegal. The GGL can initiate payment blocking, preventing transactions with illegal providers. Internet providers may also be required to block access to such websites.

The Google Problem

A quick analysis of Google search results for sports betting-related keywords reveals an alarming picture: comparison portals promoting unlicensed betting providers dominate the first page of search results. This development not only undermines the efforts of German regulators and compliant portals but also massively endangers player protection.

This issue becomes particularly evident when searching for "new betting providers"—a term with 1,000 monthly searches. The top four positions are occupied by comparison portals, all of which list unlicensed providers. This means that nearly every user searching for new betting providers first encounters illegal offerings. Established SEO analyses show that the top four positions on Google receive approximately 70% of all clicks. In this case, about 700 searchers per month are directly guided to unlicensed providers.

This phenomenon is closely tied to how security and trustworthiness impact Google rankings. Websites that meet trust signals tend to rank higher, but unlicensed providers cleverly mimic these attributes to deceive users.

Similar patterns emerge with other relevant search terms:

• For "betting providers" (4,400 monthly searches), two comparison portals with illegal offerings appear in the top 10.
• The term "sports betting providers" (900 monthly searches) leads to two comparison portals with unlicensed providers.
• For "betting bonus" (620 monthly searches), three of the top 10 portals list illegal providers.
• The keyword "betting provider bonus" (search volume: 450) includes a portal in position eight.
• Even terms like "serious betting providers" (search volume: 200) and "betting provider comparison bonus" (search volume: 10) see these portals in the top 10.

Understanding how algorithm-specific factors shape Google rankings is key to analyzing why unlicensed portals manage to dominate these searches. By optimizing for high-ranking factors, they outpace compliant portals.

Serious Comparison Portals Are Being Displaced

This dominance has far-reaching consequences. Serious comparison portals, such as MyWettanbieter.de, which exclusively feature licensed providers, are systematically pushed out of top positions. Estimates suggest that these legitimate portals lose up to 80% of potential visitors to competitors that include unlicensed providers.

The comparison portals play a particularly problematic role. They present themselves as neutral advisors but deliberately mix licensed and unlicensed providers in their comparisons. Often, unlicensed providers are even given more prominence, as they tend to pay higher commissions and offer more attractive bonuses—precisely because they are not bound by strict German regulations.

The ability of unlicensed providers to thrive in this environment illustrates the importance of content factors that influence Google rankings. Their use of persuasive and optimized content plays a critical role in securing high search engine rankings.

This situation places Google in a dilemma. On the one hand, the search engine ranks pages according to its usual criteria. On the other hand, it unintentionally contributes to the spread of illegal offerings. Addressing this issue is urgently needed to protect the regulated German sports betting market and establish fair competition.