Market entry in practice: How hard is entry, really?

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). [