At the centre of the dispute are figures published by the DHS that, according to the DSWV, “grossly exaggerate the turnover of legal sports betting providers.” The trade association claims the DHS estimated sports betting turnover at €12 billion instead of the accurately calculated €7.72 billion for 2023—an “absurd increase” of 28.6% year to year, despite the market actually shrinking by 5.4%, based on DSWV figures.
“The current calculations by the DHS inevitably raise the question: where does the enormous difference of more than four billion euros come from?” the trade association stated. “The logical conclusion can only be: the difference represents the illegal black market, which the DHS is now quantifying for the first time through its calculations.”
The DSWV warned that this distorted portrayal of the sports betting market could have consequences for many stakeholders. “The victims of this conscious or unconscious distortion by the Bremen researchers are not only the licensed providers, whose reputation is damaged by false turnover figures, but also consumers, politicians, and regulatory authorities, who are being misled about the true state of the gambling market,” the association declared.
This is not the first time the DSWV and addiction researchers have clashed over data. In 2023, the DHS claimed that the sports betting market generated €18.3 billion in wagers in 2021—a figure representing a 409.6% increase from the previous year. The DSWV called this number “incorrect” and “wildly inflated,” asserting instead that the real turnover was €9.4 billion, an increase of only 21% compared to 2020.
The disputed calculation came from Prof. Dr. Gerhard Meyer of the University of Bremen’s Institute for Public Health and Nursing Research, who derived the market size by dividing an estimated gross gaming revenue of €1.3 billion by a presumed payout ratio of 93%. The DSWV was particularly critical of the sources Dr. Meyer used to arrive at this figure: non-academic betting comparison websites such as fussballwetten.com, sportwettentest.net, and wettanbieter.de.
“These sources are completely inadequate for scientific work,” the DSWV wrote in 2023, noting that fussballwetten.com has “an incomplete imprint” and promotes offshore operators without German licenses. “Of the ‘TOP 10 betting providers’ recommended there, not a single one is licensed in Germany,” the association added. According to the site, “bookmakers can also offer bets legally and safely with licenses from Curaçao”—a claim that, in the DSWV’s view, “undermines any effort to create a legal and secure sports betting market in Germany.”
Regarding sportwettentest.net and wettanbieter.de, the DSWV noted that their anonymous author “Heinz” offers only vague claims about payout ratios. “These vary from provider to provider and from bet to bet,” the DSWV explained. “They depend on a number of factors—including market competition, tax burden, cost structure, the bookmaker’s risk appetite, and the betting behaviour of customers.”
“It is regrettable that a research institute like the Bremen Institute for Public Health and Nursing Research, which claims to conduct scientific gambling studies, would rely on sources like ‘Heinz from the internet’ as the foundation for its work,” the association stated.
The DSWV emphasized that no scientifically reliable average payout ratio exists and that the 93% figure is not realistic, particularly in light of Germany’s tax on each bet.
To support its position, the association pointed to a more transparent and robust method for calculating market size: using actual tax receipts published by the Federal Ministry of Finance. “The turnover of licensed providers can be easily and accurately tracked through officially reported tax data. Every euro wagered in Germany’s legal market is subject to a 5.3% sports betting tax. The Federal Ministry of Finance publishes figures on these taxes every month,” said the DSWV.
In a detailed rebuttal published on June 21, 2023, gambling economist Prof. Dr. Tilman Becker echoed many of the DSWV’s concerns and presented a scientific counter-analysis. “Reliable data on the sports betting market comes from tax revenue generated by the sports betting tax,” Becker explained. “This allows us to calculate the net amounts wagered by players using scientific methods.”
“It is high time for transparency and accuracy,” the DSWV concluded.
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