Distribution and platforms: Can we ship through apps and platforms?

Licensed operators in Germany face a comprehensive set of operational obligations grounded in IST2021. Mandatory integration with LUGAS — the cross-operator deposit and limit monitoring system — enforces the 1,000 euro monthly deposit limit across all operators in real time; a connection to a Save-Server system integrated into LUGAS is also mandatory. Mandatory integration with OASIS — the national self-exclusion register — is required for all licensed verticals. A certified random number generator is required for virtual-slot and online-poker operations. Virtual slots are subject to among the most restrictive technical parameters in Europe under the primary legislation: a per-spin stake limit that was EUR 1 but has, with effect from 1 July 2026, been replaced by a tiered maximum of up to EUR 5 (up to EUR 3 once the player is at least 21, up to EUR 5 after a 90-day period without signs of problem gambling), a five-second minimum spin duration, no autoplay functionality, and no jackpots. Online poker is limited to four simultaneous tables per player; video poker is not licensable under the current framework. Reporting obligations to the GGL are set per licence conditions. The advertising watershed ban from 06:00 to 21:00 applies across television, radio, and internet for virtual slots, online poker, and online casino games. Revenue-share affiliate remuneration is prohibited under sec. 5 IST2021; only fixed cost-per-click or cost-per-acquisition arrangements are permitted.