The Gemeinsame Glücksspielbehörde der Länder (GGL), Germany's federal-state gambling oversight body, has formally said that it is illegal to play the Spanish Christmas lottery El Gordo de Navidad ("El Gordo") from Germany. The notice was put on the regulator's website on November 17, 2025.
Seasonal Advertising Meets Strict Gambling Rules
As the holiday season approaches, there is a big increase in advertising for people to play El Gordo online, especially in November and December. A lot of these deals are only for persons who live in Germany. The GGL says, meanwhile, that these offers are not legal.
The main point is that the Spanish lottery is legal and exists in Spain, but German law under the Glücksspielstaatsvertrag 2021 (GlüStV 2021) forbids "second-lotteries" (Zweitlotterien) or broking schemes that let German residents play through unlicensed third parties. The GGL says that a number of online offers do not make a contract between the German player and the Spanish state lottery operator. Instead, they make a speculative wager on the outcome of El Gordo through a middleman. In Germany, its construction is not allowed, hence it is against the law.
What the GGL states
The regulator makes it clear that:
- The online deals that are being marketed are not legal in Germany because they don't have a German licence and aren't on the official whitelist of suppliers that are allowed to do business there.
- Taking part through these unregistered companies comes with a lot of hazards, such as not getting paid for wins and having your personal information used inappropriately.
- The GGL has a separate FAQ that answers important questions: Why can't people join? How does El Gordo work? What happens if someone takes part anyway?
Enforcement Measures and Legal Boundaries
For Germans who are attracted by the holiday spirit of El Gordo, the message is clear: if you play in unlicensed games, you might not get your prizes and your personal information could be at risk. The GGL also said it will take action against unlawful gaming ads and services.
The GlüStV 2021 puts tight prohibitions on arbitration or broking of gambling products that let people in Germany play without a German licence. The verdict makes clear that the most important things for regulators are protecting players, making sure licenses are clear, and setting the legal limits on who can play the lottery.
Cross-Border Lottery Trends and Consumer Risks
Every year, millions of people take part in El Gordo because of its big prize pool and fun cultural tradition. But while someone who is physically in Spain and playing through a licensed Spanish operator is legal, Germans who play through third-party online portals are breaking the law in Germany.
This shows two bigger trends for those who watch and play in Germany: cross-border lotteries are not automatically legal in Germany, and the rise of online offers aimed at German residents raises worries about regulation and consumer protection.
One GGL spokesperson said,
"Teilnahme a 'El Gordo' aus Deutschland ist illegal – wir raten dringend davon ab." It is against the law for people in Germany to take part in El Gordo. We highly warn against it.
Heightened Risks as Holiday Promotions Intensify
The GGL's warning comes at the right time: as vacation advertising for El Gordo heats up, Germans should know that taking part in illegal internet offers is not only dangerous, but also against the law under the GlüStV 2021. Because of the risk of losing money, breaking the law, and putting your data at risk, these kinds of offers are more of a trap than a fun opportunity.
In the future, users in Germany who want to play the lottery should make sure that any provider has a valid German licence and is on the official whitelist. Regulators are going to make it even harder for cross-border and second-lottery schemes to work. To keep a significant win from turning into a legal issue, you need to be careful and follow the rules.