Tens Or Better

What is Tens Or Better?

The DOCV, another trade body representing licensed online casino operators in Germany, also expressed support for the prosecutorial efforts. However, it emphasised that the raid exposed regulatory gaps which had allowed organised crime to flourish.

Kevin O’Neal, a DOCV board member, argued the scale of the investigation calls the GGL’s broader black market estimates into question. He cited the regulator’s 2025 activity report, which put the 2024 share at 23% (€547 million in gross gaming revenue), against Nielsen data suggesting a share of around 56%.

The trade body has long been critical over the discrepancy between channelisation estimates made by the regulator, and other independent reviewers.

What is Tens Or Better?

Although three-quarters of respondents rated their VIP data as good or very good, 71% reported data spread across multiple systems. Half admitted sometimes making decisions with incomplete or outdated information. 

“Silent churn” was prevalent, with nearly half (46%) stating that VIP players often or very often became inactive without prior warning. Around 48% had no indicators of players’ behavioural signals or health. Co-author Viktoriia Grygorenko, CEO at The Playa, called this finding the “clearest commercial case in the report”.

“Every other finding – portfolio overload, fragmented data, reactive workflow, no behavioural signal – resolves here, in revenue that walks out without notice, without warning and without anyone getting the chance to intervene.” 

What is Tens Or Better?

One Foundation’s operating licence was suspended for six days after the DIA identified accounting failures relating to gambling proceeds, as well as a failure to surrender a licence for one of its pokies venues when required by law.

The DIA also issued new financial guidance for class 4 operators, with the aim of providing greater clarity on their accounting requirements and an explanation of their obligations.

The department said the guidance had been designed to “improve consistency across the sector and help prevent similar issues from occurring in future”.