Bet3000 settles accounts with GGL: Open fire letter against "arbitrariness of authorities"

The Joint Gambling Authority of the federal states (GGL) is used to criticism. However, the open letter that Bet3000 addressed to the GGL a few days ago has a special quality. The sports betting provider is venting a real rage that has apparently been building up for around ten months. It has been just as long since the company's license was revoked due to technical deficiencies dating back some time.

Bet3000 has had enough - and is letting the public know in no uncertain terms. In an open letter published on May 26, 2025, the sports betting provider launched an all-out attack on the GGL. What reads like a mixture of rant and political satire is actually a bitterly serious document of frustration. The very first lines leave no doubt about the tone: this is not about diplomatic words, legal phrases or pious pleas, but about loud criticism of a system that, from the bookmaker's point of view, has gone off the rails.

The comparison with a "Kafkaesque bureaucratic nightmare", which Bet3000 even continues in literary form on its currently deactivated website, is more than just a rhetorical stylistic device. It is an emphatic but subtle formulation of the question of why the provider has been banned from the whitelist since the summer of 2024 - and whether the way in which the GGL withdrew the license can be compatible with constitutional principles. At the time, we wondered whether Bet3000 was withdrawing from the German market or whether regulatory decisions were the trigger.

The result: almost a year of standstill, a mountain of unresolved conflicts - and now a letter that escalates the situation. The explanations are really quite something. Here we take a look at what exactly Bet3000 is accusing GGL of.

Bet3000 complains about GGL's "legal confrontation course" against a "pillar of the legal German gambling market"

What Bet3000 describes as an "absurd administrative act" began with an abrupt cut:

• On July 25, 2024, the provider's license was revoked practically overnight - without warning, without a hearing, without an interview.
• The reason: technical deficiencies from the previous year. The piquant thing is that, according to Bet3000, the errors in question had long since been rectified at the time of the decision.
• However, instead of a joint clarification at eye level, a "legally confrontational course" was taken from the outset. Attempts to find an amicable solution outside the courtroom: Allegedly blocked by GGL.
• The case is now before the courts - a procedure that Bet3000 believes would never have been necessary if communication had taken place at an early stage.
• The bookmaker is particularly critical of GGL's legal interpretation: even a temporary deficiency is apparently enough to bring an economically stable company to its knees.

Ten months later, the situation remains unchanged - at least as far as the bookmaker's online presence is concerned. According to Bet3000, the state's tax losses alone amount to over 55 million euros.

From the provider's point of view, it is not just about its own business, but also about the future of the regulated market. According to the accusation, the GGL's rigorous approach is endangering the very structures that make player protection possible in the first place - and thus potentially creating space for the black market that it should actually be combating.

Speaking of which, we recently reported that the fight against illegal gambling has been enshrined in the current coalition agreement.

GGL has no understanding of order, fairness and integrity

Order, fairness, integrity - big words that the GGL confidently claims to stand for, according to Bet3000. But what do these principles mean if they are not applied in practice? This is exactly what the provider asks itself in the open letter - and doesn't hold back with sharp irony. While Bet3000 coordinates real processes, employs people and bears responsibility on a daily basis, the authority apparently remains in a bureaucratic ivory tower. It is not regulated there, but rather regimented - far removed from reality.

Perhaps the most explosive accusation concerns the GUTS's reaction - or rather non-reaction - to a comprehensive dossier that Bet3000 voluntarily submitted on February 19, 2025:

• Over 600 pages full of detailed technical analyses, error logs and concrete proposals for action - an own effort that, according to Bet3000, goes far beyond what the authority itself has ever submitted. The answer: total silence. No reference to an audit, no offer of talks - nothing.
• A few weeks later, however, the GGL published an internal document entitled "Technical Expectations", according to Bet3000 - and this was peppered with exactly the same terms, analyses and formulations that the bookmaker had previously provided. Only the logo was missing.

A coincidence? More likely, according to Bet3000's assessment, a gross violation of the principle of fair treatment of parties in accordance with Section 17 (1) VwVfG. When the provider finally demanded the return of the documents, the GGL initially refused to do so - on the grounds that it was assumed that it would be allowed to keep the files permanently. For Bet3000, this behavior is a further indication of how deep the breach of trust has gone in the meantime - and how far an authority can have moved away from a dialogue based on partnership.

Bet3000 criticizes denial of contact and sees itself as deliberately isolated

• According to Bet3000, all attempts to communicate with the GGL have come to nothing. Talks with relevant decision-makers: Rejected several times.
• Well-founded inquiries: Rejected - with reference to general reporting forms, as if there were no more responsibilities, no more names, no more people in the authority.
• The ironic point of the letter: "Perhaps a chatbot would be more efficient, because at least it would respond."

The result is sobering: no one can be reached. And if they do, the response is along the lines of: "We don't have time."

Bet3000 sees itself not only disregarded, but actively blocked. According to its own statements, the provider wants to comply with all regulations and openly coordinate with the responsible authorities. In contrast, many unlicensed platforms continue to operate unchallenged. So why is an established, licensed company with over 40 years of market presence being declared a problem?

Bet3000 publicly accuses GGL of violating the law

"Bet3000 will not bow to this behavior," is the clear statement. The provider publicly raises serious accusations - from a lack of consultation (Section 28 VwVfG) to a lack of justification (Section 39 VwVfG) and a disregard for fundamental rights (Articles 12 & 3 GG). The aim of the State Treaty on Gambling - to strengthen the legal market (Section 1 (1) GlüStV 2021) - has also been reduced to absurdity with the current approach.

The GGL, according to the tenor, violates central principles of the rule of law and willfully endangers the legal market. Bet3000 is no longer prepared to put up with this - and has announced that it will take legal action at various levels.

They have nothing to hide, but a lot to lose. And, according to the final note, this will not be accepted without action.

Bitter conclusion on an "administration that hides behind legal texts"

Source of the image: Screenshot from https://maintenance.bet3000.de/

Central text source: https://www.isa-guide.de/isa-gaming/articles/291008.html