title: Germany — Outlook: What is coming? | advennt.io canonical: https://advennt.io/jurisdictions/germany/outlook/ [Jurisdictions](https://advennt.io/jurisdictions/) [Germany](https://advennt.io/jurisdictions/germany/) Outlook Germany · Question 11 of 11 # Outlook: What is coming? Mixed · Probable · Expert approved · 4 post-review updates · Not reviewed · In expert review scope · [Back to full Germany report →](https://advennt.io/jurisdictions/germany/) Key section parameters | Jurisdiction | Germany (DE) | |---|---| | Regulator | Recorded in register | | Favourability | Mixed | | Confidence | Probable | | Review status | Expert approved · 4 post-review updates · Not reviewed · In expert review scope | | Last collected | 23 Oct 2026 | Summary answer 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… Not reviewed Information added after the 8 Jul 2026 expert review — published for currency and labelled not reviewed. 12 Oct 2026 Not reviewed 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 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 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 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. ## Full section analysis 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.