--- title: "Germany gambling licensing, cost and supervision | advennt.io" canonical: https://advennt.io/jurisdictions/germany/ source_html: /jurisdictions/de/index.html description: "Germany gambling regulation by game: 4 open · 3 restricted · 10 closed · 2 uncertain · 1 not yet assessed." generated_at: 2026-10-27T14:33:42Z content_sha256: 5c720b2d441636e900a08ee91378c2387ecff929940374e3970fd970efbd831f generator: "fe-fleet/md-twin@1.0" --- # Germany gambling licensing, cost and supervision | advennt.io [Jurisdictions](/jurisdictions/) › Germany # Germany Federal layer Large addressable market, but turnover tax and €1 spin cap make slots economics marginal; sports betting and B2B supply are the more viable routes. [4 open · 3 restricted · 10 closed · 2 uncertain · 1 not yet assessed → 20 classes](#products) Collected 23 Oct 2026 · Published 23 Oct 2026 · Changed 12 Oct 2026 [PDF](report.pdf) [Sign in for PDF](https://advennt.io/auth/) [Compare](/compare/?j=germany) ## Can we offer our product? Every product class, in fixed taxonomy order. The band is what you can do; where the recorded legal status says something the band does not, it is shown beside the product. ### Player products - CasinoProhibitedXClosed - PokerOOpen - BingoState monopolyXClosed - LotteryState monopolyXClosed - Sports bettingOOpen - Other event bettingProhibited · Models agreeXClosed - Horse and greyhound racing betting–Not yet assessed - Esports bettingRRestricted - Exchange bettingProhibited · Models agreeXClosed - Pool bettingState monopoly · Models agreeXClosedVaries by form · 1Horse racing totalisator: restricted - Virtual event bettingProhibited · Models agreeXClosed - Fantasy sportsProhibited · Models agreeXClosedVaries by form · 1Classic season long: outside_perimeter - Skill gamesNot yet regulated?Uncertain - Prediction marketsProhibited · Models agreeXClosed - SweepstakesOutside the regulatory perimeter · Models agreeOOpen - Free playOutside the regulatory perimeter · Models agreeOOpen ### Supply roles - Software / B2BNot yet regulated?Uncertain - Affiliate marketingRRestricted - Payments for gamblingRRestricted ### Settlement rail - Crypto gamblingProhibited (not actively enforced)XClosed Class-level certainty is graded for 8 of 20 classes. ## Board briefing Germany is a large but commercially constrained regulated market: GGL federal licensing exists, but a 5.3% turnover tax and €1 spin cap suppress margins and channelisation. #### What has changed - GGL opened a comprehensive online-slots review in April 2026 (consultation expected Q3 2026); the Federal Administrative Court (March 2025) struck down the IP-blocking legal basis pending amendment. #### What to do now - Model effective burden under the turnover tax before committing; for slots, the €1 spin cap plus 5.3% stake tax may make competitive RTP impossible. Budget the €5m guarantee and LUGAS/OASIS integration lead-time. B2B suppliers can enter without a licence by supplying GGL-licensed operators. #### What to watch - The GGL slots review outcome (recommendation early 2027) and the mandatory GlüStV evaluation due December 2028, which may relax stake/deposit limits or revisit the tax basis. ## 11 answers, each dated and graded The weather grades favourability for an operator, not legality: legality is the product table above. The left rule is our confidence: solid confirmed, dashed probable, dotted uncertain. 01 · What kind of market is this? ### Overview Mixed Germany's gambling regime remains anchored in the Gluecksspielstaatsvertrag 2021 (GlueStV 2021), administered by the Gemeinsame Gluecksspielbehoerde der Laender (GGL), a public-law institution seated in Halle (Saale), Saxony-Anhalt. The GGL whitelist as of 21 July 2026 lists approximately 95 license… Full analysis · 116 words Germany's gambling regime remains anchored in the Gluecksspielstaatsvertrag 2021 (GlueStV 2021), administered by the Gemeinsame Gluecksspielbehoerde der Laender (GGL), a public-law institution seated in Halle (Saale), Saxony-Anhalt. The GGL whitelist as of 21 July 2026 lists approximately 95 licensed providers for virtual slot machines, 14 for sports betting, and 2 for online poker, with no operators listed for online-casino table games or poker under state-concession routes. The dominant recent development is GGL's liberalisation of the virtual-slot stake limit into a tiered model effective 1 July 2026, set against political pushback from the 99th Health Ministers' Conference (GMK) over player-protection gaps. The tension between commercial liberalisation and political criticism of enforcement adequacy is the defining regulatory dynamic. - 5.3% turnover (stake) tax — not GGR — compresses RTP and margins - €1 max stake per spin and 5-second minimum spin on slots - Low channelisation driving players to offshore operators - Online casino table games prohibited federally Not reviewed Information added after the 8 Jul 2026 expert review — published for currency and labelled not reviewed. 4 Sep 2026 Not reviewed Read update GGL's Tätigkeitsbericht 2025 records a deliberate shift in 2025 from permit-issuance toward structured, ongoing supervision of already-licensed operators, conducted through supervisory dialogues and active market-observation measures, alongside continued investment in technical and data infrastructure to support future regulatory decisions. Against that backdrop, GGL introduced new opt-in €3 and €5 online-slot stake and deposit tiers above the standing €1 GlüStV 2021 cap, effective 1 July 2026 and time-limited to 31 December 2027, requiring individual per-operator permission. Together these developments describe a regulator consolidating its supervisory posture over the existing licensed market rather than expanding or restricting who may operate within it, consistent with Germany's standing civil-law licensing-stack framework under GlüStV 2021. Confirmed Not reviewed 1 post-review update · Not reviewed [Read full analysis & tables →](/jurisdictions/germany/overview/) 02 · Can we get a licence? ### Licensing and regulation Mixed Gaming law in Germany differs between states, though relevant legislation has been passed by way of an Interstate Treaty bringing some uniformity. In Germany, the relevant state treaties have been lined up since 2008, while the last one in its current form entered into force on 1 July 2021. Since th… Full analysis · 1914 words Gaming law in Germany differs between states, though relevant legislation has been passed by way of an Interstate Treaty bringing some uniformity. In Germany, the relevant state treaties have been lined up since 2008, while the last one in its current form entered into force on 1 July 2021. Since then, the range of permissible games of chance has been expanded from sports betting and exceptions for lotteries and horse-race betting, which are of minor relevance to private operators, to virtual slot machine games and online poker. Online casino table games form an exemption, as these are subject to a numerical limitation, where online casino licences are only issued to a limited extent per state. The number varies between 0 and 5, depending on the number of casinos in the respective province (sec. 22c (1) No. 2 Interstate Treaty on Gambling 2021 - IST 2021). Gambling in Germany takes place both online and terrestrially. In the online sector, payment is made with non-anonymous means of payment; in the terrestrial sector, payment in cash is also possible. In principle, gambling is allowed, but is subject to varying degrees of restrictions to protect young people and addicts. The degree of restrictions depend on the degree of dangerousness to minors and addicts/players. As a result, slot machine games and poker games, both terrestrial and online, tend to be restricted more than sports betting and lotteries. Betting: By way of background, the centralised responsibility for the regulation of sports betting, as well as horse race betting, has been devolved to the Joint Gambling Authority in Saxony-Anhalt. Necessary documents and certificates that enable the authorities to assess the realms of permissible gambling include among other documents an excerpt from the register of companies, an excerpt from the Central Commercial Register in Germany, a certificate of Good Conduct / police record. Of particular importance is the subject of responsible gambling. This requirement is also reflected in different ways in the various concepts to be submitted. This includes an IT security concept (covering IT security and data protection), social concept (describing protection of minors and responsible gaming measures) or payment processing concept (which contains minimum requirements for payment processing, for example, an overview showing all deposit methods offered or an explanation regarding the prohibition of granting credit). In principle, the maximum deposit per month is EUR 1,000 (sec. 6 (1) 2 Interstate Treaty 2021). Deviating deposit option up to an amount of € 30,000 can be applied for. For this purpose, a forecast must be submitted containing percentage information on turnover and gaming stakes. If approved by the GGL, increased deposits require financial capacity from players. The operator is obliged to check these thoroughly. Furthermore, the operator has to carry out a comprehensive monitoring of players who have been granted an increased deposit limit. In addition, certain requirements are extremely difficult to meet. These include, for example, the insurance of players’ funds for EUR 5 million. This amount poses a particular challenge for small companies. The applicant needs to declare, in which way he wants to provide the security. Examples are bank guarantee, owner savings book, in this context special insurance policies required by the regulatory authority, are also difficult to obtain. Bingo: Under the current Interstate Treaty on Gambling, the offering of bingo is not licensable for private operators. Casino: The operation of land-based casinos in some states is reserved for the public authorities, other states provide a limited number of licences for private operators. The number of casinos allowed per state is, however, limited and will vary between the states. The Interstate Treaty 2021 provides for a monopoly of the states and/or of land-based casinos on operating live casinos and table games online, though the compliance of this restriction with EU law seems questionable. Separate from this are the regulations on slot machines, both in terrestrial offerings and in web-based form. These can be offered by private operators to the public and are not subject to a state monopoly or numerous clauses. Nevertheless, the general regulations of the Interstate Treaty 2021 must be taken into account. In addition, there are further restrictions on the game-related stakes, the maximum playing time, the permissible advertising, jackpot prohibitions and certain information and transparency obligations of the operators, as stipulated in the federal Gaming Ordinance (‘Spielverordnung’). Online Casino products, in particular so-called bank or table games e.g. roulette, black jack, baccarat or similar have become licensable nationwide with the new Interstate Treaty 2021. However, the number of licenses are limited to the number of terrestrial operations. Lottery: Lotteries are subject to a state monopoly, which means that the operation of lotteries is exclusively reserved for the state-owned lottery companies, which the German states are very protective of. With relation to lotteries, private operators may only apply for brokering licences, which allow them to sell lottery tickets on behalf of the state lottery companies. In respect of the general prohibition of operation and brokerage of online games of chance, lotteries are one of the exemptions made by the Interstate Treaty in this context. Poker: Online poker has become licensable for the first time after the Interstate Treaty on Gambling came into force on 1st July 2021. Consequently, private operators can now also offer poker on the internet. However, some restrictions apply that are both general in nature and special in character. Online poker is hence subject to a general monthly deposit limit of EUR 1,000 (A deviation from the monthly deposit limit of up to € 30,000 per month can also be applied for here since 1 January 2023. If an increased deposit limit has been approved and is to be granted to a player, the operator must check the financial capacity and - if the player has it - carry out extensive monitoring) as well as time limits that are supposed to interrupt the gaming session after 1 hour. Furthermore, operators must ensure that only natural persons play against each other and that they are only assigned to one table at a time. The table assignment must be carried out by means of audited random generators; the player himself must not be able to influence this. Simultaneous play of several poker games is prohibited. However, the authority responsible for issuing the licence may exceptionally permit simultaneous play at up to four virtual tables (sec. 22b (5) 2 Interstate Treaty 2021). Skill games: Skilled games are not subject to the scope of German gambling laws. German law consequently does not provide a licensing regime for the operation of skilled games. Software/B2B is not subject to the scope of the current Interstate Treaty on Gambling; the regulation neither requires nor stipulates a B2B licence. The Joint Gambling Authority (GGL) in Halle, Saxony Anhalt is managing all online licence application processes be it for online sports betting, online horse betting, online poker or virtual slot machine games. Only for online casino games (typical table and banker players) are the authorities of the federal states responsible. Thus, there is no national licensing process for online casino table games (as opposed to online slots – see casino product section) with each State deciding whether to grant licences to private operators or to have a state-owned or licenced monopoly. Period of licence & renewal process A licence is usually valid for 5 years. Renewals of licences are valid for 7 years, and so on. Application timeframe and phrases There are no deadlines to apply for gambling licences. However, a licensing procedure for online gambling permits for sports betting, virtual slot machines and online poker is an extensive administrative procedure, which in practice takes at least 9 months. Furthermore, and on a general basis, the competent authorities publish so-called application guidelines, which enumerate and summarise all necessary documents and contents for a sufficient application. Once the application has been submitted, ideally, the authority would then issue a licence based on the application. However, this period tends to usually be more onerous. The authorities will reach out to the operators approximately 2 to 4 times during this period with subsequent requests, meaning to clarify certain details within the application or to extend certain concepts and documents. In total, a licencing procedure can be pinned down to approximately 3 months of preparations, followed by submission and another 9-10 months of back and forth with the authorities, until a licence is issued. Documents & type of information needed to support application To obtain a licence, a number of conditions must be met. A peculiarity of licensing procedures in Germany is the requirement to submit so-called ‘concept’ documents (i.e., comprehensive descriptions of the gambling operation to be licensed that cover these aspects), such as: 1)an AML concept, including a risk assessment and AML policies and guidelines, 2)a payment processing concept, detailing the PSPs and adherence to regulatory requirements to payments methods to be made available to the customer, 3)a profitability concept, including a business plan for the licensing period, 4)an IT security concept covering IT security and data protection, 5)a social concept (sec. 6 Interstate Treaty on Gambling) describing protection of minors and responsible gaming measures, 6)a document laying out compliance with transparency requirements vis-à-vis the customer (also referred to as the ‘transparency concept’). With regard to the individual reliability of the applicant entity, the operator applying for a licence will have to provide evidence in the form of, for example, criminal records, CVs and qualifications of the relevant individual. There is no personal licensing requirement for key functions and managers though. Corporate entities may be considered unreliable if they have been fined for misconduct in business by public authorities, for example. In addition to the aforementioned concepts, economic and legally relevant information on the company must be provided. This includes a variety of comprehensive documents, including: 1)a presentation of the complete ownership and shareholder structure, disclosure of trustee relationships. 2)statement on how the financial security for a minimum 5 million EUR will be provided. 3)a copy of commercial registration in Germany. 4)a clearance certificate from the tax authority, excerpt from debtors’ register or an application letter, including a list of all authorised representatives and VAT ID. Applicant considerations Applicants need to be resident in the EU or EEA. Generally, the representatives or staff of online operators do not need to be German speaking except for the company’s AML Officer and Deputy AML Officer. ## Infrastructure Operators have to connect to several state-run servers and databases that intend to restrict a player’s behaviours in three ways: Firstly, operators need to integrate the nationwide player barring system (“OASIS”) which logs all banned players and helps avoid approaching, messaging, or allowing those banned players to participate in any form of gambling. Second and thirdly, the server system “LUGAS” contains two databases, the activity file and the limit fine. This monitors the activity and spending behaviour of players, ensuring that deposit limits are adhered to on a cross-operator level and that players don’t gamble for long periods without being forced to take breaks in between. As well as preventing simultaneous gambling on more than one operator’s website. ## Integrations As stated above, operators must connect to several state-run databases to ensure safer gambling and prevention of addiction. The integration with those servers is either an application requirement or, in the case of the player barring system, a licence requirement. Software certification Operators need to prove that their technical platforms are ISO 27001-certified. If they implement digital card payment methods, they need to submit PCI-certifications of such, too. Not reviewed Information added after the 8 Jul 2026 expert review — published for currency and labelled not reviewed. 4 Sep 2026 Not reviewed Read update GGL's 30 June 2026 decision introduced new opt-in €3 and €5 online-slot stake and deposit tiers, sitting above the standing €1 GlüStV 2021 cap, effective 1 July 2026. Access to the higher tiers requires individual per-operator GGL permission and the tiers are time-limited to 31 December 2027, marking this as a bounded, reversible pilot rather than a permanent change to the deposit and stake cap regime. As a delegated administrative decision issued under the enabling GlüStV 2021 statute, the instrument carries mixed durability: the underlying statutory cap remains durable primary legislation, while this specific relaxation is an administrative-level permission that expires by its own terms. The standing licensing framework and issuing authority (GGL) are otherwise unchanged this cycle; no development affecting B2B/B2C licence requirements, applications, renewals, or suspension/revocation powers surfaced. Confirmed Expert approved 1 post-review update · Not reviewed In expert review scope [Read full analysis & tables →](/jurisdictions/germany/licensing/) 03 · How hard is entry, really? ### Market entry in practice Mixed Regulated market Gaming law in Germany differs between states, though relevant legislation has been passed by way of an Interstate Treaty bringing some uniformity. In Germany, the relevant state treaties have been lined up since 2008, while the last one in its current form entered into force on 1 Ju… Full analysis · 801 words Regulated market Gaming law in Germany differs between states, though relevant legislation has been passed by way of an Interstate Treaty bringing some uniformity. In Germany, the relevant state treaties have been lined up since 2008, while the last one in its current form entered into force on 1 July 2021. Since then, the range of permissible games of chance has been expanded from sports betting and exceptions for lotteries and horse-race betting, which are of minor relevance to private operators, to virtual slot machine games and online poker. Online casino games form an exemption, as these are subject to a numerical limitation, where online casino licences are only issued to a limited extent per state. The number varies between 0 and 5, depending on the number of casinos in the respective province (sec. 22c (1) No. 2 Interstate Treaty on Gambling 2021 - IST 2021). Before the new state treaty came into force, the heads of government of the federal states had agreed on a so-called transitional regime in order to be able to draw important conclusions from market and consumer behaviour and pave the way to legality for active online gambling operators. Since November 2020, this transitional regime has provided that illegal services could already be made available on the market under the protective umbrella of a sort of toleration, in which regulatory enforcement was waived provided certain rules were adhered to by the operator. Large parts of the industry have made use of this. Under the new regime of the Interstate Treaty on Gambling 2021, the majority of them have filed applications for the granting of the corresponding licences and quite a few operators have been issued one. With the complete transfer of responsibility to the new Joint Gambling Authority of the federal states (the ‘Gluecksspielbehoerde der Laender’ or ‘GGL’) on 1 January 2023 the transitional regime ended. German players show interest in online slots, casino games and online betting. The GGL's 2025 activity report, published 3 July 2026, records the permitted German gambling market at EUR 14.4bn in gross gaming revenue for 2025 (down from a prior-year comparator in the same report), of which EUR 3.5bn (24%) was generated online and the remainder through land-based channels. By segment, gaming-hall and pub slot machines (Geldspielgeräte) accounted for the largest share at EUR 4.9bn (34%), followed by state lotteries (DLTB) at EUR 4.2bn (29%), sports betting (including internet horse-race betting) at EUR 1.9bn (13%), casinos (including online casino games) at EUR 1.5bn (11%), class and social lotteries at EUR 1.2bn (9%), virtual slots and online poker at EUR 0.6bn (4%), and horse-race betting at EUR 0.04bn (0.3%). Online casino games specifically contributed only EUR 2 million, reflecting that only a single operator was active online in that category in 2025. On the black market, the GGL's 2025 report cites a 2026 study based on a 2,000-person survey estimating illegal online gross gaming revenue at EUR 547 million for 2024, equivalent to approximately 4% of the total permitted market — materially lower than the 25% figure previously used in this document. The German Sports Betting Association (‘Deutscher Sportwettenverband’ – ‘DSWV’), the trade body of licensed sports betting operators and affiliated businesses, has previously taken the position that the unregulated market is substantially larger, at more than 50%; that divergence between the regulator's survey-based estimate and industry's own assessment remains unresolved. On online casino specifically: Schleswig-Holstein has issued four online casino licences to private operators by public tender since September 2024; North Rhine-Westphalia passed its enabling law on 17 February 2026 permitting up to five online casino licences with a ten-year term each, its online casino ordinance entered into force in August 2026, and a tender is expected to follow in the following months. Most other federal states continue to run either a state monopoly or no regime at all, and Bavaria remains the only state live with a state-run online casino offering. Attractions - Still expanding regulated market in country with a wealthy population. Evolving regulation: Relaxing regulations as time goes on (e.g. deviation from the EUR 1 stake per spin for virtual slot games as well as deviation of the monthly deposit limit for virtual slot games and online poker up to an amount of € 30,000 since beginning of 2023). In general a supportive regulatory authority. Advertising (with limitations) is possible for licenced operators. Challenges - In the online sector (sports betting, virtual slot machines, online poker): difficult market entry due to high security deposit required (at least five million EUR) and burdensome compliance with regulations for licensing procedures. In the case of online casino games, the number of licences per federal state is also very limited. Partially high technical requirements, especially for the connection to the central files supervision system (‘LUGAS’ cross-operator deposit and activity file). [ Probable Expert approved In expert review scope [Read full analysis & tables →](/jurisdictions/germany/market-entry/) 04 · What do the licences cost? ### Licence fees Mixed Initial application fees can reach approximately €185,000 plus a stake-volume component, with an annual supervisory fee calculated on GGR/risk profile. A minimum €5 million security deposit / bank guarantee is required as financial security for obligations. Additional compliance costs arise from LUG… Full analysis · 47 words Initial application fees can reach approximately €185,000 plus a stake-volume component, with an annual supervisory fee calculated on GGR/risk profile. A minimum €5 million security deposit / bank guarantee is required as financial security for obligations. Additional compliance costs arise from LUGAS/OASIS integration, independent testing and audits. Probable Not reviewed [Read full analysis & tables →](/jurisdictions/germany/fees/) 05 · What is the tax take? ### Tax Unfavourable The licensing fees vary depending on the average sum of stakes and on the respective products, as some are not licensable and therefore no fees or costs may be charged, but in general for licensable products: Application fees Applicants do not have to pay an application fee. Licensing fees Licensin… Full analysis · 969 words The licensing fees vary depending on the average sum of stakes and on the respective products, as some are not licensable and therefore no fees or costs may be charged, but in general for licensable products: Application fees Applicants do not have to pay an application fee. Licensing fees Licensing fees are regulated in sec. 9a (4) Interstate Treaty: For granting a licence for operating games of chance, for approved or expected gambling or betting stakes: Up to EUR 40 million, a fee amounting to 0.2 per cent of the gaming or betting stakes, at least 100 euros; Over EUR 40 million up to EUR 65 million, a fee of EUR 80,000 plus 0.16 per cent of the stakes exceeding EUR 40 million; Over EUR 65 million up to EUR 130 million, a fee of EUR 120,000s plus 0.1 per cent of the stakes exceeding EUR 65 million; or Above EUR 130 million, a fee of EUR 185,000 plus 0.06 per cent of the stakes exceeding EUR 130 million, shall be levied on the basis of the sum of the authorised or anticipated gaming or betting stakes in all participating countries. In addition, the regulator will levy fees and expenses for their other duties as stipulated in the State Treaty on Gaming. Minimum guarantee The insurance of players’ funds for EUR 5 million. This amount poses a particular challenge for small companies. The applicant needs to declare, in which way he wants to provide the security. Examples are bank guarantee, owner savings book, in this context special insurance policies required by the regulatory authority, are also difficult to obtain. There is no specific capitalisation requirement, though the GGL will evaluate during the licensing process whether an applicant has sufficient ‘own funds’ – e.g. via cash flow of existing own operations or via a group entity – to operate the business to be licensed according to the parameters set out in the business plan. Bingo could be offered by state-run operators only. Accordingly, licensing fees are not relevant to private operators. Casino: In case the casinos will be operated by private operators, such costs shall be imposed on them in accordance with the General section. Lottery: As lotteries are exclusively state-operated, they are not licensable, and no fees are payable. Skill games: Since skilled games are not regulated under the Interstate Treaty of 2021, the law does not stipulate fees. Software/B2B: Since software / B2B suppliers are not regulated under the Interstate Treaty of 2021, the law does not stipulate fees. Gambling taxation is stipulated in a variety of federal and state laws. Online sports betting, horse-racing and lottery taxation are subject to the federal Horse-Race Betting and Lottery Act. Simultaneous to the Interstate Treaty 2021, virtual slots and online poker were included in the Horse Race Betting and Lottery Act and are therefore subject to the gambling-specific tax rate. The federal VAT Act stipulates a VAT exemption for games of chance that are subject to the Horse-Race Betting and Lottery Act. The gambling-specific tax has to be declared on a monthly basis by way of a self-declaration procedure. In this procedure, the operator has to include the taxable amount in the form provided by the tax authorities and calculate the tax amount. The self-declarations are deemed tax returns meaning they will become legally binding (unless they are appealed within one month from submission). Since the German Fiscal Code generally stipulates in sec. 40a that not owning a local licence does not result in being exempt from taxation for an otherwise taxable behaviour in Germany, tax authorities may assume unregulated operations that are not subject to a specific gambling tax (see below) to be liable for VAT. Not reporting taxes in full and in due time may result in criminal liability for tax fraud. Accordingly, operating unregulated gambling in Germany may come with an ancillary liability for non-compliance with German tax laws. Betting is subject to a 5.3% tax on stakes, meaning that winnings cannot be deducted from the tax base. The operator (not the broker or betting shop owner) is the tax debtor, but the operator can choose to forward the tax burden to the customer. The so-called ‘Odds Reduction Model’ provides for a tax-optimised way of forwarding (parts of) the tax burden to the customer by imposing a fee, e.g., of 5.3% on winnings. The tax authorities have approved the Odds Reduction Model. Bingo: As the operation of bingo is qualified as a lottery, a tax of 20% on stakes applies in accordance with sec. 29 Horse-Race Betting and Lottery Act. Casino taxes are stipulated in the local Casino Acts of the federal states as well as casino licences, and vary considerably in terms of rate and structure. Most casino taxes will be in excess of 30% of GGR and will be structured to have tiered increases of the tax rate depending on GGR per year the casino operation yields. As a consequence, tax rates for land-based casinos in excess of 70% are possible if a casino is very profitable. Lottery: State lotteries are subject to a tax of 20% on stakes according to sec. 29 Horse-Race Betting and Lottery Act. Poker: Online Poker is subject to tax pursuant to the Horse-Race Betting and Lottery Act, namely to a 5.3% tax rate. The same applies to virtual slot machine games. Skill games: There are no skilled games specific taxes in Germany, but skilled games may be subject to VAT depending on the way the game is monetised. In general, it will depend on whether a skilled game qualifies as an ‘electronically provided service’ and whether taxable consideration for that service is paid by a German consumer to the operator. Software/B2B: Since software/B2B suppliers are not regulated under the Interstate Treaty of 2021, the law does not stipulate fees. Confirmed Expert approved In expert review scope [Read full analysis & tables →](/jurisdictions/germany/taxes/) 06 · Can we move player money? ### Payments and banking Mixed Land-based operators can offer every payment form including cash payments, except for crypto-currencies. Online operators must restrict their payment methods to transactions involving certified and licensed bank institutions seated in the EU/EEA. Cash payments are not allowed, neither are crypto cu… Full analysis · 201 words Land-based operators can offer every payment form including cash payments, except for crypto-currencies. Online operators must restrict their payment methods to transactions involving certified and licensed bank institutions seated in the EU/EEA. Cash payments are not allowed, neither are crypto currencies. In case of customer cards, a closed loop must be ensured for anti-money laundering reasons. GGL enforcement against payment intermediaries intensified recently without a change to the underlying statutory basis. The GGL's accessory-liability powers under sec. 9 IST2021 extend to payment service providers facilitating deposits to unlicensed German-facing gambling operators, and the 2025 enforcement cycle saw explicit targeting of payment blocking and hosting providers as part of the anti-illegal-market campaign. This is likely rather than confirmed. The practical implication for payment infrastructure is that PSPs processing gambling-related transactions for German-facing brands face escalating exposure to GGL blocking referrals and reputational risk if they cannot confirm the downstream operator's GGL licensing status. The draft Zweiter Änderungsstaatsvertrag, if enacted, would further embed network-level blocking obligations on internet access providers, reinforcing the payment-blocking vector at the infrastructure layer. No new statutory payment-method permissions or withdrawal-obligation changes have been identified recently; the payment-flow risk picture is one of intensifying enforcement under existing statutory authority. Not reviewed Information added after the 8 Jul 2026 expert review — published for currency and labelled not reviewed. 4 Oct 2026 Not reviewed Read update GGL joined a coordinated statement among European gambling regulators targeting unlicensed online gambling, the advertising that promotes it, and the payment flows that sustain it. Under the standing GlüStV 2021 framework, unlicensed remote gambling targeted at or accessible to players in Germany is prohibited, and this prohibition extends to associated payment-flow facilitation. The coordinated statement signals an emerging cross-border effort to disrupt payment access for non-compliant operators rather than a purely domestic German initiative, and it should be read alongside the broader rise in GGL prohibition-proceeding volume as part of a single tightening enforcement posture. No specific German payment-blocking action tied to this statement has yet been evidenced, and the joint-statement text itself was not directly retrieved this cycle, so the precise mechanics of any resulting payment-flow disruption remain to be confirmed. Probable Expert approved 1 post-review update · Not reviewed In expert review scope [Read full analysis & tables →](/jurisdictions/germany/payments/) 07 · Can we advertise? ### Marketing Mixed Advertising and marketing of gambling overall must be considered to be subject to a restrictive regime and influenced by a number of laws and regulations including the Interstate Treaty on Gambling, the Gambling Acts of the individual states, the Act Against Unfair Competition and specific laws for … Full analysis · 631 words Advertising and marketing of gambling overall must be considered to be subject to a restrictive regime and influenced by a number of laws and regulations including the Interstate Treaty on Gambling, the Gambling Acts of the individual states, the Act Against Unfair Competition and specific laws for the protection of children and minors. Online Marketing According to the Interstate Treaty 2021, in general, online advertising of gambling offerings is only allowed for games of chance that can be legally offered in Germany (Section 5 (7) of the Interstate Treaty 2021). Betting: For sports betting, special regulations are provided for in the Interstate Treaty on Gambling 2021. Immediately before or during the live broadcast of sporting events on the broadcasting channel, no advertising for this sporting event may take place. Advertising featuring active athletes and officials is also prohibited. In stadiums and sports facilities, advertising in the form of umbrella brands is permitted on jerseys, boards, scoreboards, and the floor of the playing field (including underfloor advertising in the case of ice hockey). Unlike online casino games, virtual slot machines and online poker (for which advertising is prohibited between 6 a.m. and 9 p.m.), there is no time limit for advertising on television or the internet for sports betting. However, the ban on advertising for virtual slot machine games and online poker is being challenged before the administrative courts. Alongside those general provisions stated in the Interstate Treaty itself, sports betting operators will find more detailed and extensive provisions regarding legal advertising as part of their sports betting licences. Bingo: Advertising for bingo is allowed to the state operator a restricted extent. In particular, the Federal Court of Justice (BGH) has limited the possibilities of advertising jackpot winnings of state-run bingo. Bingo companies may only provide factual information about possible high winnings. The court already declared images of cheering people in the advertising or slogans with the invitation to join in the game to be inadmissible in 2010 (AZ: I ZR 149/08). Casino: The ban on privatised casino offerings and the associated ban on advertising has been heavily criticised under EU law, even prior to the Interstate Treaty 2021 coming into force. In this respect, it is argued that the total ban is disproportionate since it is unfit to achieve the Interstate Treaty objectives, namely consumer protection and the channelling of players towards the regulated market (sec. 1 Interstate Treaty on Gambling) and therefore violates operators’ freedom to provide services (Art. 56 TFEU) under European law. Although casino games may be operated on the internet under the new Interstate Treaty on Gambling 2021, those operations are strictly limited to the number of licensed terrestrial operations. Therefore, it is likely that advertising online casino games by private operators will hardly play a role in future, especially against the background of the advertising ban for online casino games on television and the internet between 6 a.m. and 9 p.m., which also applies to virtual slot machine games and online poker. Lottery: Advertising for the lottery is allowed to a restricted extent. In particular, the Federal Court of Justice (BGH) has limited the possibilities of advertising jackpot winnings of state lotteries. Lottery companies may only provide factual information about possible high winnings. The court already declared images of cheering people in the advertising or slogans with the invitation to join in the game to be inadmissible in 2010 (AZ: I ZR 149/08). Poker: Since poker has become admissible for private operators, the realms for legal advertising were broadened largely. Licensed operators are allowed to promote their products, as far as those that the regulator in Saxony-Anhalt has permitted. Simultaneously, advertising for virtual slot games is assessed and handled. Between 6 a.m. and 9 p.m., advertising for online poker is prohibited on television and the internet. Confirmed Expert approved In expert review scope [Read full analysis & tables →](/jurisdictions/germany/marketing/) 08 · What must the platform meet? ### Technical compliance Mixed Licensed operators must integrate with LUGAS (cross-operator deposit/limit monitoring) and OASIS (national self-exclusion register), and use certified RNG systems. Virtual slots are capped at €1 max stake per spin with a 5-second minimum spin duration, no autoplay and no jackpots. Online poker is li… Full analysis · 69 words Licensed operators must integrate with LUGAS (cross-operator deposit/limit monitoring) and OASIS (national self-exclusion register), and use certified RNG systems. Virtual slots are capped at €1 max stake per spin with a 5-second minimum spin duration, no autoplay and no jackpots. Online poker is limited to four simultaneous tables; video poker is not licensable. IP-blocking power exists but is currently unenforceable pending a legislative amendment per the Federal Administrative Court. Confirmed Not reviewed [Read full analysis & tables →](/jurisdictions/germany/technical/) 09 · Can we ship through apps and platforms? ### Distribution and platforms Mixed 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-S… Full analysis · 228 words 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. Probable Expert approved In expert review scope [Read full analysis & tables →](/jurisdictions/germany/distribution/) 10 · How hard does the regulator enforce? ### Enforcement Mixed Regulatory bodies Since 1st July 2022, the Joint Gambling Authority (“GGL”) has gradually replaced the Saxony-Anhalt State Administration Office as the body charged with taking action against unlicensed cross-state operations and activities across Germany. The regulator can carry out their supervis… Full analysis · 1030 words Regulatory bodies Since 1st July 2022, the Joint Gambling Authority (“GGL”) has gradually replaced the Saxony-Anhalt State Administration Office as the body charged with taking action against unlicensed cross-state operations and activities across Germany. The regulator can carry out their supervision through various measures. For one thing, operators are required to report on a regular basis about various facts and figures in relation to their operations. Reporting requirements require figures regarding players, stakes, turnover, etc., as well as findings on results and consequences of their advertising as well as safer gambling ambitions & measures. Furthermore, the authority could at any time request more detailed documents and evidence on the information. Additionally, the regulator is able to monitor certain game-related facts in any case, because operators have to be connected to LUGAS (player activity monitoring, limit monitoring) and OASIS (nationwide player barring database). The operator is liable for breaches of gambling regulations, but liability may also extend to advertising partners and PSPs and affiliated companies. The GGL have the option to publish the names of operators reprimanded for breaches of regulation on a ‘naming and shaming’ list on their website. Illegal gambling as well as advertising for games that have not been licensed are triggers for enforcement. Still, branding of unregulated operations remains visible in some sports competitions available to German audiences, such as Formula 1 broadcasts. Furthermore, allowing payment methods that do not correspond with current AML-regulations trigger enforcement measures. Tax liabilities do so, as well. According to the regulator's activity report for 2024 (published June 2025), GGL issued 231 cease-and-desist proceedings that year, 83 of which related to the operation of illegal gambling and the remainder to advertising for illegal games of chance; the regulator's activity report for 2025, published 3 July 2026, records that by the end of 2025 a cumulative 1,843 illegal websites had become unreachable from Germany as a result of cease-and-desist orders or network blocking, 2,662 websites of illegal operators or advertisers had been reviewed, and 178 payment-blocking measures had been carried out. These figures should be used in preference to any differing trade-press figures elsewhere in this document purporting to describe the same 2025 report. "Unauthorised gambling”, meaning non-German licensed gambling operations, and related advertising can be enforced against based on administrative law, administrative offence law or criminal law. Potential sanctions range from paying a fine to a worst-case imprisonment of three months to five years. In administrative offence and criminal law, profits may be “skimmed off” under certain conditions. The GGL have tried forcing the hand of local prosecutors in the city of Halle i.e. the prosecutor’s office at the seat of the authority by filing hundreds of criminal charges against unregulated online operations, however, the regulator admitted in their annual report that many of them had been dismissed because that prosecutor did not consider the criminal charges to be enforceable against offshore operators. Trade bodies of licensed operators therefore have called for more effective enforcement against the black market. Betting: Online sports betting is not a key enforcement priority for German regulators. Since the start of the licensing process for sports betting in 2020, the former Hessian regulator had assumed a centralised responsibility for regulating sports betting which should bar other regulators from having a divergent enforcement approach. The GGL has established a system of pre-approval of new bet types and markets to be offered, giving the regulator the opportunity to prevent non-compliant bet types and markets at an early stage. As a consequence, betting on sports events or competitions that may be susceptible to match-fixing, such as amateur sports and lower leagues, is banned. With respect to preventing match-fixing, licensed operators are required by the GGL to participate in an early warning system, such as the International Betting Integrity Association, again trying to prevent match fixing issues at an early stage. Bingo: Since bingo falls under the state monopoly, there is almost no enforcement against bingo operators. Casino: In principle, regulatory enforcement against unauthorised operations and distributions differs in the states and some “hardliner” states such as Saarland had issued far-reaching interdiction orders in 2020. In addition, it is possible for gambling regulators under the Interstate Treaty to authorise each other to furnish one interdiction procedure for multiple states and law enforcement seems to be on the rise lately. The Gambling Acts of the individual German states authorise regulators to sanction illegal gambling and related advertising as an administrative offence with administrative fines. The value of fines that can be imposed can be up to EUR 500,000 as per the various Gambling Acts of the German states. Liability for administrative offences does not only pertain to legal representatives of companies who are personally involved in unlawful behaviour of the company but may also lie with the legal entity represented by that individual. In contrast, liability under the German Criminal Code only pertains to individuals and not to legal entities. Lottery: Since the lotteries fall under the state monopoly there is almost no enforcement against lottery companies, except in the case of so-called “secondary lotteries” which – unlike lotteries and sports betting – may not be operated or brokered on the internet. Secondary lotteries clearly have been an enforcement priority for German regulators for over a decade. Poker: The GGL generally claims to enforce against illegal online operations, though cases of enforcement against online poker operations have not become publicly known as yet. Skill games: Skilled games fall outside of the scope of German gambling laws. It appears as if the regulator’s enforcement efforts are currently not focused on the skill game sector, though GGL officials have indicated that their authority may take a closer look at the skill games sector in the near future to ascertain that skill games operations do not veer into the gambling sector. Software/B2B: Software and B2B suppliers fall outside the scope of German gambling laws. Still, the GGL continually reviews compliance of games and software used in licensed operations, though the any issues will usually be addressed with the licensee and not with software / B2B supplier (the exception being PSPs where the regulator is supposed to address issues directly with the PSP under the regulations). Not reviewed Information added after the 8 Jul 2026 expert review — published for currency and labelled not reviewed. 12 Oct 2026 Not reviewed Read update Germany's gambling enforcement regime rests on the permit requirement in GlüStV 2021, with the Gemeinsame Glücksspielbehörde der Länder (GGL) empowered to issue orders against unlicensed operators on that statutory basis. That mechanism suffered a material setback in 2026: the Verwaltungsgericht Halle blocked three GGL enforcement directives, in decisions of 6 August (7 B 491/25 HAL, 7 B 492/25 HAL) and 24 August (7 B 62/26 HAL), each citing a structural deficit in the evidentiary and data-access basis the GGL relied upon. The rulings constrain how the GGL can use its permit-requirement enforcement tool against unlicensed operators without altering the underlying statutory prohibition. In response, a GGL board member has publicly called, within the context of the ongoing GlüStV evaluation, for expanded and faster-acting decision-making powers to address what was described as a highly dynamic illegal market. That call is a public institutional position tied to a live evaluation process due by 31 December 2026, not yet a statutory change. Together, the court decisions and the GGL's public response point to a widening gap between the authority's enforcement mandate and its current practical capacity to exercise it against unlicensed operators. 28 Sep 2026 Not reviewed Read update GGL enforcement intensity against unlicensed online gambling operators has risen sharply: prohibition proceedings increased from 68 in 2022 to 287 in 2025, and approximately 6,300 websites had been reviewed by end of 2025 for illegal gambling offers or associated advertising, a more than fourfold increase in proceedings within three years. Separately, the Bundesgerichtshof designated case I ZR 216/25 a Leitentscheidungsverfahren, with a hearing held 17 September 2026 on whether players may reclaim losses from operators that lacked German authorisation. Numerous stayed cases await this outcome, meaning the ruling will apply well beyond the individual case. The two developments together point to intensifying enforcement exposure on two fronts: rising administrative prohibition activity against unlicensed operators, and a pending judicial determination of retrospective civil liability for historical unlicensed play. No specific licence-revocation event was evidenced this cycle against a currently licensed GGL operator; the enforcement pressure described here is directed at unlicensed or historically unlicensed activity rather than at compliant licence-holders. 4 Sep 2026 Not reviewed Read update GGL imposed a confirmed €250,000 coercive fine (Zwangsgeldbescheid) on the rapper Capital Bra for livestreamed promotion of illegal online gambling, an enforcement action targeting promotional and affiliate-style intermediary conduct rather than an operator directly. GGL also intensified enforcement tied to the 2026 World Cup, probable to include international regulator cooperation with the IOC, FIFA and UEFA on information exchange concerning illegal betting, confirming that major sporting events function as enforcement trigger points within the German system. Both actions sit within Germany's civil-law enforcement-theory pattern: unlicensed gambling activity is itself an offence under GlüStV 2021 §4, prosecuted primarily through administrative rather than criminal channels, with accessory liability extending to intermediaries who promote illegal operators. No enforcement action against a licensed operator's core betting product surfaced this cycle; the escalation is concentrated on promotional actors and offshore illegal-market activity around a major event window. Confirmed Expert approved 3 post-review updates · Not reviewed In expert review scope 8 enforcement events [Read full analysis & tables →](/jurisdictions/germany/enforcement/) 11 · What is coming? ### Outlook Mixed Bingo: There are no legislative plans to remove the state monopoly on operating bingo. Casino: The Interstate Treaty on Gambling 2021 re-categorises games of chance. Thus, by definition, online casinos should only include games such as Roulette and Blackjack (now defined as “virtual bank holder gam… Full analysis · 241 words Bingo: There are no legislative plans to remove the state monopoly on operating bingo. Casino: The Interstate Treaty on Gambling 2021 re-categorises games of chance. Thus, by definition, online casinos should only include games such as Roulette and Blackjack (now defined as “virtual bank holder games”). This classification is of particular importance with regard to licensing, as online casino games for private operators are available only in extremely limited numbers and may be organised predominately by state-owned casinos. Applicant entities cannot apply for a fully-fledged online licence but only for the licensing of so-called “virtual slot machines” similar to arcades/gaming halls in the land-based sector. Smaller operators have been negatively affected by the requirements, specifically the security in the form of a bank guarantee of at least EUR 5 million. Unfortunately, there are no plans to amend this requirement, e.g. to the scale of the business. Lottery stays in the hands of the state, at least as far as the organisation is concerned. Licences can be granted for self-distribution as well as for brokerage. Poker: Deviations from monthly €1000 deposit limits have been applied for, allowing deposits of up to €30,000 per month. The number of online poker licensees has increased to five at the Software/B2B: Software and B2B suppliers are not subject to German gambling law. This is likely to change in the coming years, though Germany might not introduce a full B2B licensing system but some form of certification. Not reviewed Information added after the 8 Jul 2026 expert review — published for currency and labelled not reviewed. 12 Oct 2026 Not reviewed Read update The Second Amending Treaty (Zweiter Glücksspieländerungsstaatsvertrag, 2. GlüÄndStV) was signed by all sixteen Länder between 2 and 26 March 2026 but remains unratified at the individual parliamentary level. Niedersachsen's cabinet released its ratification bill for stakeholder consultation (Verbandsbeteiligung) in July 2026 and had not sent it to the Landtag as of early September 2026, illustrating the pace at which individual Länder are moving. Under Article 2(1) of the Treaty, its amendments enter into force only the day after the last Land deposits its ratification instrument with the chair of the Interior Ministers' Conference, so the commencement date remains indeterminate and depends on the slowest of the sixteen legislatures. Separately, the GGL is seeking expanded enforcement powers through the ongoing GlüStV evaluation process, due to conclude by 31 December 2026, a request raised in the same period as the VG Halle rulings constraining the authority's current enforcement mechanism against unlicensed operators. 28 Sep 2026 Not reviewed Read update The GGL marked five years since the GlüStV 2021 State Treaty took effect and has publicly called for more flexible statutory tools ahead of the treaty's first comprehensive evaluation. The Administrative Board chairmanship rotated to Berlin's Christian Hochgrebe on 1 July 2026, specifically timed ahead of this evaluation cycle. No draft amendment text has surfaced yet, so the direction any eventual reform will take remains unresolved: the regulator has signalled it wants expanded flexibility, but has not yet articulated what that would look like in statutory terms. This is a live reform question rather than a settled trajectory, and operators should watch for the emergence of draft amendment text as the first concrete signal of direction. 19 Sep 2026 Not reviewed Read update Three forward signals define the German reform horizon this cycle. The Bundesgerichtshof has scheduled a leading-decision hearing for 17 September 2026 in case I ZR 216/25, concerning recovery of losses from illegal online gambling, a ruling that could materially affect civil-recovery exposure for operators of illegal online gambling. Separately, and at lower confidence, the Advocate General in CJEU Case C-440/23 is reported in secondary commentary to have assessed Germany's pre-2021 blanket online-gambling prohibition as incompatible with the EU freedom to provide services, a claim not independently verified against a primary CJEU record this cycle. Finally, the GMK's June 2026 unanimous finding of systemic player-protection gaps creates political tension with GGL's stake-limit liberalisation and raises the prospect that the liberalisation could be revisited before its scheduled 31 December 2027 expiry. Together these three threads represent the principal sources of forward regulatory uncertainty for the German market. 4 Sep 2026 Not reviewed Read update The IMK endorsed a draft Second State Treaty in June 2025 that would give GGL statutory IP-blocking authority curing the gap exposed by the Federal Administrative Court's March 2025 Lottoland ruling, expand GGL's power to seek foreign-regulator reliability information, and replace TMG references with DSA-aligned language, while explicitly excluding advertising from the blocking scope. This remains not yet enacted, with the underlying treaty text unverified against a primary Länder legislature source this cycle. Separately, GGL is conducting its own 2026 evaluation of the GlüStV 2021 framework, including possible adjustment of deposit and stake limits and channelization measures, running independently of the treaty-amendment process. Neither track has produced a binding change yet, but together they represent the two live reform vectors that would most affect a market-entry calculation going forward. Probable Expert approved 4 post-review updates · Not reviewed In expert review scope [Read full analysis & tables →](/jurisdictions/germany/outlook/) Evidential record & source register 2 enforcement · 26 red flags · 13 sources · Expand full record ## Enforcement record What the regulator has actually done, newest first. 2 recorded events. - 19 Mar 2025Bundesverwaltungsgericht · GGL IP-blocking power / access providersConfirmedSource 4 · T1Source 6 · T3 - 31 Dec 2024GGL · Unlicensed online operators and advertisersConfirmedSource 8 · T3 ## What gets operators fined 26 red flags (10 high, 9 medium, 5 low) and 6 controls that address them. - high€1 max stake per spin on slotsSeverely caps slot revenue per session vs offshore competitors.Source 6 · T3 - high€1,000 cross-operator monthly deposit limitCaps player spend across all licensed operators via LUGAS.Source 7 · T3 - highOnline casino table games prohibited federallyRoulette/blackjack not federally licensable; state-by-state patchwork only.Source 8 · T3 - highAffiliate revenue-share remuneration bannedForces fixed-fee acquisition models, constraining performance marketing.Source 6 · T3 - high€5m security depositHigh capital lock-up barrier to entry.Source 10 · T3 - highPayment-block orders to PSPsGGL can order PSPs to cut off illegal gambling transactions.Source 8 · T3 - highAML fines up to €1mGwG §56 fines up to €1m or twice the benefit.Source 8 · T3 - highLow channelisation (~35%)Most demand leaks offshore, undermining the licensed market.Source 5 · T3 - highCivil chargeback/refund mass litigationPre-licensing losses subject to player refund claims (BGH suspended pending CJEU).Source 6 · T3 - highOperator revenue decline (bet-at-home -28%)Major licensed operators reporting material German revenue declines attributed to offshore migration.Source 5 · T3 - medium5-second minimum spin durationReduces play velocity and revenue.Source 5 · T3 - medium06:00-21:00 advertising watershedDaytime advertising ban for slots/poker/casino limits reach.Source 6 · T3 - medium231 cease-and-desist proceedings in 2024Active enforcement tempo against unlicensed operation and advertising.Source 8 · T3 - mediumNo autoplay / no jackpots on slotsProduct feature restrictions reduce competitiveness.Source 8 · T3 - mediumIn-play betting unclearSome in-play bets prohibited without clear definition, creating compliance ambiguity.Source 8 · T3 - mediumGlüStV evaluation due 2028Framework under review; rules may change materially.Source 5 · T3 - mediumLand-based casino tax 20-80%Very high state-level casino taxation.Source 9 · T3 - mediumInfluencer advertising restrictedBeyond-scope influencer promotion banned.Source 6 · T3 - mediumLUGAS integration frictionIntegration is a technical bottleneck for new entrants; operators not connected cannot operate.Source 9 · T3 - lowVideo poker not licensableLimits poker product variants.Source 8 · T3 - lowMax 4 simultaneous poker tablesConstrains multi-tabling and poker revenue.Source 9 · T3 - lowSocial/political betting prohibitedNon-sport event betting prohibited.Source 8 · T3 - lowPool/tote betting state monopolyTote remains monopolised.Source 8 · T3 - lowCrypto not a recognised funding methodCrypto funding unavailable for licensed play.Source 7 · T3 - critical5.3% turnover tax on stakesTax on gross stakes (not GGR) can equal or exceed actual GGR, making competitive RTP mathematically impossible.Source 9 · T3 - critical§284 StGB criminal exposureUnlawful organisation of gambling is criminal.Source 8 · T3 ### Controls - 001LUGAS integrationConnect to cross-operator deposit/limit monitoring system before launch.Source 9 · T3 - 002OASIS integrationIntegrate with national self-exclusion register and enforce exclusions.Source 13 · T3 - 003Deposit-limit enforcementEnforce €1,000 cross-operator monthly deposit limit with 7-day delay on upward changes.Source 7 · T3 - 004Slot product complianceEnforce €1 spin cap, 5-second spin, no autoplay, no jackpots.Source 6 · T3 - 005Affiliate remuneration controlUse only fixed-fee affiliate links; ban revenue-share remuneration.Source 6 · T3 - 006AML/KYC programmeMaintain GwG-compliant CDD, monitoring and SAR reporting to the FIU.Source 8 · T3 ## Worked scenarios 5 entry scenarios, each with the move we would make. #### MGA-licensed slots operator wants to serve German players without a GGL licence. Serving DE without GGL licence is unauthorised gambling exposing the operator to cease-and-desist, payment blocks and §284 StGB risk. Do this: Obtain a GGL VAS licence or geo-block German traffic. Source 8 · T3 #### Operator modelling slot P&L under the turnover tax. 5.3% of gross stakes can equal or exceed actual GGR, forcing lower RTP than offshore rivals. Do this: Stress-test margin at realistic RTP; consider sports betting where economics are less punitive. Source 9 · T3 Source 11 · T3 #### B2B platform supplier entering Germany. No GGL B2B licence exists; supplier need only ensure the operator's licence covers the supplied product. Do this: Contract only with GGL-licensed operators and verify product-category coverage. Source 6 · T3 #### Operator wants to offer online roulette to German players. Online table games are not federally licensable; only certain states (e.g. SH) issue private licences via tender. Do this: Pursue a state-level tender where open, or exclude table games. Source 8 · T3 #### Operator structuring affiliate acquisition for Germany. Revenue-share remuneration is banned; only fixed-fee (CPC/CPA) arrangements are lawful, and watershed/influencer rules apply. Do this: Restructure affiliate contracts to fixed-fee and audit creative against advertising rules. Source 6 · T3 ## What we looked for and could not find Confirmed absence is a finding of its own. These are the questions we searched and could not answer from a citable source, with the searches we ran. Never behind the paywall. Market opportunity. no T1 regulator-published total online GGR/market-size figure located; relying on T2 press (~€3.5bn market, ~€1.1bn sports GGR). - searched: GGL Jahresbericht 2024 Glücksspielmarkt Umsatz - searched: Germany online gambling GGR 2024 regulator statistics - searched: GGL annual report market size online gambling - checked: gemeinsame-gluecksspielbehoerde.de Competitive landscape. no published T1/T2 figure for unlicensed/black-market share; GGL estimates ~4% while industry (DSWV) disputes as too low — no agreed figure. - searched: Germany unlicensed gambling market share percentage 2024 - searched: GGL black market estimate channelisation rate - searched: DSWV black market Germany online gambling share - checked: igamingbusiness.com ## Source register Every source on a four-step tier scale. A claim is never shown at a stronger tier than the source it cites. 13 sources · 4 tier 1 · 9 tier 3 No. Source Tier Verification 1 GLUSTV-2021 T1 of 4 Source 1 · Open in drawer → 2 RENNWLOTTG-2021 T1 of 4 Source 2 · Open in drawer → 3 GGL-PORTAL T1 of 4 Source 3 · Open in drawer → 4 BVERWG-IPBLOCK-2025 T1 of 4 Source 4 · Open in drawer → 5 BSN-SLOTS-REVIEW-2026 T3 of 4 Source 5 · Open in drawer → 6 LEGAL500-DE-GAMBLING T3 of 4 Source 6 · Open in drawer → 7 IGB-CHANNELISATION-2025 T3 of 4 Source 7 · Open in drawer → 8 ICLG-DE-2026 T3 of 4 Source 8 · Open in drawer → 9 CHAMBERS-DE-2025 T3 of 4 Source 9 · Open in drawer → 10 ALTENAR-DE-GUIDE T3 of 4 Source 10 · Open in drawer → 11 GM-TAXMODEL-2026 T3 of 4 Source 11 · Open in drawer → 12 ESI-TAXREV-2025 T3 of 4 Source 12 · Open in drawer → 13 LEGALPILOT-DE-2026 T3 of 4 Source 13 · Open in drawer →