Germany — Gemeinsame Glücksspielbehörde der Länder (GGL) — Standards Explorer
All 41 German standards, organised by theme
A searchable, filterable index of Germany's online-gambling rulebook, drawn from the Glücksspielstaatsvertrag 2021 (GlüStV), the Gemeinsame Glücksspielbehörde der Länder (GGL) technical guidelines for LUGAS and Safe-Server, the Rennwett- und Lotteriegesetz (federal gambling-tax act), and the residual Länder rules for online casino table games. Standards are grouped by theme, tagged editorially and deep-linkable.
The State Treaty on Gambling 2021 (GlüStV) is Germany's federal master-law for all gambling, ratified by each of the 16 Länder. It created the Gemeinsame Glücksspielbehörde der Länder (GGL), the central regulator in Halle (Saale), with exclusive competence over online virtual slots, online poker, nationwide sports betting oversight and illegal-market enforcement. Online casino table games remain Länder competence.
4 standards3 player-flagged
75%
player-flagged
Regulatory risks this theme addresses
Treating Germany as a single uniform market — table games are state-by-state
Operating in Germany without a GGL licence or a valid Länder concession
Mis-identifying which regulator has jurisdiction over a product line
Glücksspielstaatsvertrag 2021 (GlüStV) 2
GlüStV
State Treaty on Gambling 2021 — the federal master law
Player Rights
The Glücksspielstaatsvertrag entered force on 1 July 2021 and for the first time creates a nationwide licensing regime for virtual slots, online poker and sports betting. It binds all 16 Länder, supersedes the earlier patchwork of state-by-state tolerance, and is the source of every downstream GGL rule. Section 32 requires the Länder to jointly evaluate the Treaty by 31 December 2026.
Requirements
Build product and compliance roadmaps against the consolidated GlüStV text, not superseded state regimes
Track the mandatory Länder evaluation landing end-2026 for potential amendments to deposit cap, IP-blocking and advertising rules
Treat all operator conduct in Germany as federal-level unless a Land has an explicit competence carve-out
Re-read the Treaty whenever a new product is added to a licence
§ 32
Mandatory evaluation of GlüStV by 31 December 2026
The Länder must jointly evaluate the Treaty five years after entry into force, with a report due end-2026. The evaluation is expected to examine black-market channelisation, the €1,000 monthly deposit cap, the LUGAS parallel-play rule, advertising and sponsorship, and replacing the IP-blocking basis struck down by the Federal Administrative Court in March 2025.
Requirements
Brief leadership on the likely scope of the GlüStV review before end-2026
Model scenarios for deposit-cap and advertising changes during planning
Subscribe to GGL and Länder publications for review progress updates
Preserve flexibility in product and marketing contracts to absorb Treaty amendments
Gemeinsame Glücksspielbehörde der Länder (GGL) 2
§§ 27a–27q
GGL as the central federal regulator
Player Rights
Sections 27a to 27q of GlüStV establish the Gemeinsame Glücksspielbehörde der Länder, headquartered in Halle (Saale) and fully operational since 1 January 2023. The GGL licenses virtual slots, online poker and nationwide sports betting, operates LUGAS and OASIS, enforces against the illegal market, and oversees advertising. It does not license online casino table games, land-based casinos, Spielhallen or state lotteries — those remain Länder responsibilities.
Requirements
Identify which vertical falls under GGL versus a Land for every product offered
Maintain a single regulator-relations owner responsible for GGL correspondence
Map Land-level regulators where online casino table games are in scope
Respond to GGL supervisory inquiries within stated deadlines, typically two to four weeks
Whitelist
GGL Whitelist of licensed operators
Affiliate Rules
The GGL maintains a public, filterable whitelist of every licensed operator by vertical — sports betting, virtual slots, online poker, lotteries, horse-race betting. From 2024 the whitelist is an interactive online tool rather than a static PDF. Any operator not on the whitelist is by definition operating illegally in Germany.
Requirements
Verify every B2B counter-party, payment processor and affiliate against the live GGL whitelist
Monitor for new whitelist entries when evaluating market-entry competitors
Link to the whitelist from operator responsible-gambling and footer pages where appropriate
Record whitelist checks as part of AML and supplier due-diligence
B
Theme B
Vertical-specific licensing
GlüStV licenses each vertical separately — virtual slots under §22a, online poker under §22b, sports betting under §§21/21a, and online casino table games under §22c on a Länder basis. Each vertical carries its own cap list, product constraints and tax treatment, so a single operator often holds three or four licences at once.
7 standards7 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
Running a mechanic (e.g. autoplay, jackpot) that is banned in the licensed vertical
Accepting bets on event types outside the GGL catalogue
Assuming a Schleswig-Holstein licence covers the rest of Germany for online table games
Section 22a licenses online reproductions of terrestrial slot machine games, for an initial term of five years (renewable for seven). The licence is product-specific: table games, live dealer content, casino-banker poker variants and sports-betting side-products cannot be offered on a §22a licence.
Requirements
Hold a GGL §22a licence before accepting German players for virtual slot play
Segregate virtual slots from table-game, live-casino and poker offerings on separate brands or tabs
Budget for a five-year initial / seven-year renewal licensing cycle
Notify the GGL of any material game-catalogue change at least four weeks in advance
§ 22a caps
Slot mechanic caps: €1 stake, 5-second spin, no autoplay, no jackpots
Game DesignRG CriticalPlayer Rights
Every virtual slot under §22a must cap the stake at €1 per spin, enforce a minimum 5-second cycle per spin, disable autoplay, and exclude jackpot and bonus-buy features (including progressive jackpots). These are hard product constraints, not guidelines, and are tested as part of Safe-Server certification.
Requirements
Hard-code a €1 maximum stake per spin, with no per-player override
Enforce a 5-second minimum spin cycle server-side, not just in the UI
Remove all autoplay, turbo-spin and feature-buy controls from the German game build
Exclude all jackpot, progressive-jackpot and ante-bet mechanics from the German game catalogue
Submit the modified build to an accredited testing lab for the Safe-Server sign-off
Online-Poker — §22b 1
§ 22b
Online poker: player-vs-player only, four-table cap, random seat allocation
Game DesignRG CriticalPlayer Rights
Section 22b licenses non-banked poker (cash and tournaments). Banker-against-player variants such as Casino Hold'em and 3-Card Poker are excluded. A player may play a maximum of four tables simultaneously, and the operator must allocate seats randomly — players cannot pre-select table, stakes or opponents. Bots, CPUs and cloned personas are prohibited.
Requirements
Restrict the German catalogue to non-banked poker variants only
Enforce a four-table concurrent-play cap per authenticated player
Allocate table seats at random — no player-selectable lobby filter for table
Detect and block bots, cloned personas and prohibited assist-tools
Participate in the €1,000 cross-operator deposit cap via LUGAS like slots
Sportwetten (Sports Betting) — §§21, 21a 2
§ 21
Sports betting licence and event-catalogue discipline
Game DesignPlayer Rights
Sections 21 and 21a license fixed-odds betting on the outcome of sports events, online and retail. Betting on non-sports events — politics, entertainment, finance, secondary lotteries — is prohibited. Permitted bet types are listed in the GGL Ereignis- und Wettarten-Katalog; offering an off-catalogue market triggers enforcement and licence risk.
Requirements
Configure the bet-builder and manual-market tools against the current GGL Ereignis- und Wettarten-Katalog
Remove every non-sports, political and novelty market from the German offering
Provide a change-management process for new catalogue additions issued by GGL
Maintain a single source of truth mapping internal market IDs to catalogue permissions
§ 21a
Live betting: final-result and next-scoring-event only
Game DesignRG Critical
In-play betting under §21a is restricted to the final result of the event and, for selected low-scoring sports (notably football and ice hockey), the next scoring event. Handball, basketball and other high-scoring sports are effectively excluded from next-score markets. Betting on minor events (throw-ins, corners, bookings) is prohibited.
Requirements
Configure the in-play market tree to expose only final-result and permitted next-scoring markets
Apply sport-specific logic so next-score markets open only for football and ice hockey
Exclude corner, throw-in, booking and similar minor-event markets from the German offering
Audit retail SSBT bet-slip options against the same §21a constraints
Online casino table games — §22c (Länder) 2
§ 22c
Online casino table games — state-by-state licensing
Player RightsGame Design
Virtual table games (roulette, blackjack, baccarat, live-dealer) and online casino are licensed by individual Länder, not the GGL. Each Land decides between a Spielbank monopoly model and a tender with up to as many concessions as it has land-based casinos. Cross-Land operation requires a separate licence per Land.
Requirements
Identify each Land's table-game model before market entry: monopoly Spielbank or tender concessions
Apply separately to each target Land — there is no federal online casino licence
Connect each Land licence to LUGAS and OASIS exactly as GGL licensees do
Build a per-Land geo-gating layer at registration and at deposit
SH · NRW
Schleswig-Holstein and NRW: the two Länder with commercial tenders
Player Rights
Schleswig-Holstein was the first Land to open a commercial online-casino tender; in September 2024 it awarded four private licences (Tipico, BluBet, Cashpoint, Skill on Net) plus one to Spielbank SH. Nordrhein-Westfalen has prepared a tender for up to five concessions, expected to run into late 2025/2026. Most other Länder remain Spielbank-monopoly.
Requirements
Monitor the Schleswig-Holstein and NRW tender notices for renewal and entrant windows
Budget separate application fees and compliance resource for each Land tender
Treat an SH licence as covering only SH players — geo-block elsewhere
Track the monopoly-Land Spielbank timelines where they may open to private competition
C
Theme C
Cross-operator player-protection infrastructure
Germany's cross-operator layer is the most distinctive part of the framework. OASIS holds a nationwide self-exclusion file; LUGAS enforces a €1,000 monthly deposit cap and a strict no-parallel-play rule across every licensed site; the Safe-Server mirrors each operator's session and transaction data to the GGL in near real-time. Together they make the German regime behave more like a single account than a market.
9 standards9 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
Allowing an OASIS-excluded player to register or deposit anywhere across the estate
Breaching the €1,000 cross-operator monthly deposit cap
Allowing concurrent active sessions across verticals or operators
OASIS — nationwide self-exclusion file 2
§§ 8, 8a–8d
OASIS: the cross-operator exclusion register
RG CriticalPlayer Rights
OASIS, operated by the GGL, is the single national exclusion file. Every online licensee, land-based casino, Spielhalle and betting shop must query OASIS before onboarding a customer and before any session. Self-exclusion (§8a) runs for a minimum of three months with no upper bound; third-party exclusions (family, operator-initiated) run for a minimum of twelve months. The register held more than 350,000 active exclusions at the end of 2024, with 303,876 new requests that year alone.
Requirements
Hit OASIS before every account creation, login and deposit attempt
Reject registration and terminate any active session for a listed player within minutes
Operate a documented Fremdsperre workflow so staff and family members can trigger exclusion
Log every OASIS query and outcome for the retention window required by the GGL
Do not offer marketing, bonuses or reactivation offers to OASIS-listed persons
Panik-Taste
Permanent panic button for a 24-hour self-exclusion
RG CriticalPlayer Rights
Every licensed online gambling site must display a permanently visible panic button that, on a single click, triggers an immediate 24-hour self-exclusion via OASIS. The button must remain visible during game play, at deposit and at session.
Requirements
Render the panic button persistently in the site header and in the game client
Fire a 24-hour OASIS exclusion and terminate any active session on click
Test the panic button as part of every regression and game-release cycle
Measure and report panic-button activations in the monthly RG dashboard
LUGAS Aktivitätsdatei — no parallel play across operators
RG CriticalPlayer Rights
Section 6h prohibits concurrent active play. LUGAS's Aktivitätsdatei brokers a single active session per player across every licensed site and every product vertical. An attempt to start a second session on another operator or another product must be blocked until the first session ends.
Requirements
Integrate with the Aktivitätsdatei via the GGL-issued API credentials before go-live
Call session-start and session-end atomically at login, logout and timeout
Block any second session-start call for the same player-ID with a clear user message
Ensure retail and mobile clients share the same session-state under the hood
§ 6c
€1,000 monthly cross-operator deposit cap
RG CriticalPlayer Rights
Section 6c imposes a hard €1,000 cap on deposits across all licensed operators combined per calendar month, enforced in real time via the LUGAS Limitdatei. Operators may permit up to €10,000 a month (or €30,000 in documented exceptional cases) only after enhanced affordability and solvency checks and active risk-monitoring.
Requirements
Register every deposit attempt with the LUGAS Limitdatei before crediting the player account
Reject or cap the transaction when the cross-operator limit would be breached
Implement the €10,000 and €30,000 uplift only with documented affordability evidence and approval
Make the current month's available limit visible to the player
Retain evidence of uplift assessments for the GGL retention window
§ 6h
Cross-product concurrency ban
RG CriticalGame Design
A single authenticated session may only serve one vertical at a time. Slots, poker and sports betting cannot be consumed in parallel within the same session, and the LUGAS Aktivitätsdatei enforces the constraint across branded skins belonging to the same operator group.
Requirements
Force the player to close their active vertical before switching to another product
Use a single authenticated session across sister brands to avoid fan-out cheating
Expose the active-vertical state in the operator Safe-Server feed
Design multi-product UX with a hard state transition, not background tabs
Duty of care — identification, monitoring, social concept 4
§ 4(5)
Full KYC before play — 18+, OASIS, identity proof
RG CriticalPlayer Rights
Section 4(5) requires full identity verification before any real-money play. Acceptable methods include VideoIdent, eID, bank-account verification, or comparable e-ID schemes. Age must be confirmed as 18+ and the verified identity must be checked against OASIS at onboarding.
Requirements
Block all real-money play until a primary KYC method has completed successfully
Reject any onboarding where the verified age is under 18
Cross-check the verified identity against OASIS at onboarding and at login
Retain KYC artefacts for the statutory period (typically 10 years)
§ 6i
Algorithmic early-risk detection (Früherkennung)
RG Critical
Section 6i requires operators to monitor player behaviour for early-warning indicators of problem gambling — chasing losses, session length, deposit-frequency spikes, cancelled withdrawals, nocturnal play — and to intervene with messages, limit reductions, cooling-off or referrals.
Requirements
Operate a documented early-risk detection model reviewed at least annually
Trigger tiered interventions — soft message, hard limit, mandatory cool-off — when indicators fire
Record every intervention and its outcome for GGL audit
Train customer-facing staff to escalate visible risk indicators manually
§ 6
Social concept (Sozialkonzept) and staff training
RG CriticalPlayer Rights
Every licensee must submit and operate a Sozialkonzept — a social concept covering problem-gambling awareness, staff training, player risk communications, self-assessment tools and signposting to help. The social concept is part of the licence file and must be kept current.
Requirements
Draft a Sozialkonzept aligned to the GGL template and submit with the licence application
Deliver annual RG training to every customer-facing and compliance role
Publish self-assessment tools and helpline signposting in a prominent footer element
Review and re-submit the Sozialkonzept after any material product change
§ 6g
Visible cumulative net-loss display
Player RightsRG Critical
The player's cumulative net deposits and net loss for the current month must be clearly visible throughout the session. The data must reconcile with the LUGAS Limitdatei figures and must survive across sister-brand sessions.
Requirements
Render the current month's net deposit and net loss in the persistent session frame
Reconcile the displayed figures with the LUGAS Limitdatei every session-start
Preserve history across skins and clients belonging to the same operator
Surface the figures inside the panic-button and reality-check modals
D
Theme D
Advertising & marketing
Section 5 of GlüStV is among the most constraining advertising regimes in Europe. It imposes a 9pm–6am broadcast window for slot, poker and casino advertising, restricts live-event and athlete endorsement, and bans any promotion of unlicensed operators. Influencer rules have been clarified by the OVG Magdeburg ruling of December 2023.
7 standards7 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
Running a slot or casino ad before 9pm on any broadcast or mainstream internet channel
Using an active athlete as a sports-betting brand ambassador
Promoting an affiliate or programme partner that is not on the GGL whitelist
Section 5 GlüStV — the advertising framework 4
§ 5(1)
The 9pm to 6am broadcast window for slots, poker and casino
Bonus & AdsPlayer Rights
Section 5(1) restricts TV, radio and mainstream internet advertising for virtual slots, online poker and online casino to the nine-hour window between 9pm and 6am. Sports-betting advertising is broader in tolerance but is also constrained around live event broadcasts.
Requirements
Schedule all slot, poker and casino creative inventory inside the 9pm–6am window
Apply day-parting controls to programmatic and YouTube / Meta campaigns
Geo-target the constraint to Germany only — do not over-block
Archive served-creative logs for potential GGL enquiries
§ 5(2)
Live-event advertising restriction
Bonus & Ads
Sports-betting advertising is prohibited on the same broadcast channel in the immediate run-up to and during the live sports event being shown. The aim is to break the direct link between viewing and betting.
Requirements
Suppress sports-betting creative on channels broadcasting the same live event
Apply broadcast black-out lists to both linear and streaming platforms
Document the black-out workflow in the media plan for each campaign
Audit vendor compliance quarterly
§ 5(3)
Ban on active-athlete and official endorsement
Bonus & AdsAffiliate Rules
Advertising for sports betting using active athletes, referees or other sports officials is prohibited. Retired athletes remain permitted. Kit and perimeter sponsorship by umbrella brand are still permitted; a full ban on sports sponsorship was proposed in 2024 and rejected.
Requirements
Vet every ambassador contract against active-status rules for athletes and officials
Scope jersey and perimeter activations to umbrella brand, not the gambling brand, where required
Monitor the 2026 GlüStV review for a renewed sponsorship-ban proposal
Train marketing and sponsorship staff on the §5(3) distinctions
§ 5(7)
Promoting unlicensed operators is prohibited
Bonus & AdsAffiliate Rules
Any advertising, affiliation or promotion of gambling operators that are not on the GGL whitelist is prohibited. The prohibition extends to affiliate networks, media buyers and influencers. Criminal exposure follows under §§284–287 of the German Criminal Code.
Requirements
Build a pre-publish whitelist check into the affiliate and programmatic stack
Terminate affiliate partners that continue to promote unlicensed operators
Include a whitelist warranty in every affiliate, media and influencer contract
Keep a legal hold on campaign logs for 10 years
Targeting, bonuses and influencer rules 3
Minors
Advertising must not target or appeal to minors
RG CriticalBonus & AdsAffiliate Rules
Creative that targets persons under 18, or that is disproportionately likely to appeal to them, is prohibited. OVG Magdeburg's December 2023 ruling clarified that influencer advertising is only permissible inside the 9pm–6am window and must be fully scripted and controlled by the licensee.
Requirements
Vet every creative against a minor-appeal rubric before release
Bound influencer contracts to the 9pm–6am window and require licensee-approved scripts
Exclude cartoon, game-like and youth-coded motifs from the German catalogue
Request audience-demographic attestations from influencer partners
Bonuses
Bonus offers must be transparent and non-misleading
Bonus & AdsPlayer Rights
GGL guidance requires every bonus to carry prominent wagering, expiry and eligibility terms. Misleading 'free money' framing and any offer that induces chasing losses are prohibited. Bonuses counted against the €1,000 deposit limit must be treated consistently with LUGAS rules.
Requirements
Disclose wagering multiplier, expiry and eligibility adjacent to every bonus offer
Remove 'free money', 'guaranteed' and similar misleading language from German creative
Design bonus mechanics so they cannot induce loss-chasing
Treat bonus-derived stakes consistently with the LUGAS deposit cap
Affiliates
Affiliate partners are in scope — every time
Affiliate RulesBonus & Ads
Affiliate, comparison and streaming partners are treated by the GGL as extensions of the licensee. Every partner's conduct — time-of-day, influencer, targeting, whitelist compliance — is attributable back to the operator.
Requirements
Operate a managed affiliate programme with mandatory onboarding and quarterly audits
Require every partner to maintain a log of served creative and time-of-day
Terminate partners for repeat breach; document the termination in the licence file
Include a warranty and right-to-audit clause in every affiliate contract
E
Theme E
Payments
Section 6d restricts payment methods to those compatible with real-time deposit controls and onboarding checks. Credit-card deposits are effectively prohibited for slots and casino; crypto and anonymous payments are prohibited across the board; and the GGL holds a statutory power to order payment providers to block transactions to unlicensed sites.
3 standards3 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
Accepting a credit-card deposit for virtual slots or online casino
Accepting crypto or anonymised payment methods
Ignoring a §9(1) no. 4 GGL payment-blocking order
Permitted and prohibited payment methods — §6d 2
§ 6d
Permitted payment methods for GGL-licensed sites
RG CriticalPlayer Rights
Section 6d effectively limits deposits to SEPA direct debit and credit transfer, debit cards, and a narrow set of regulated e-wallets (PayPal, where supported). The operator must be able to tie every payment instrument back to the verified account holder.
Requirements
Restrict the German cashier to SEPA debit/credit, debit card and regulated e-wallets
Reject deposits where the instrument owner does not match the account holder
Disable instant third-party top-up or voucher methods that cannot tie back to KYC
Reconcile every deposit with the LUGAS Limitdatei registration
§ 6d
Credit cards, crypto and anonymous payments are off-limits
RG CriticalPlayer Rights
Credit-card deposits are effectively prohibited for virtual slots and online casino. Cryptocurrency, prepaid anonymous vouchers and any other payment method that cannot be reconciled to a verified identity are prohibited for every GGL-licensed product.
Requirements
Remove credit-card rails from the cashier for slots and online casino
Block all cryptocurrency and anonymous voucher deposits at the PSP layer
Refresh the cashier PSP mix against GGL guidance at least twice a year
Notify the GGL of any new deposit method before it goes live in Germany
Payment-blocking orders 1
§ 9(1) no. 4
GGL power to order payment-blocking against unlicensed sites
Player Rights
Under §9(1) no. 4 GlüStV, the GGL may order banks and payment service providers to refuse transactions to or from unlicensed operators. The power was upheld by the Verwaltungsgericht Halle in 2024 and is now the primary enforcement lever for the illegal market, after IP-blocking was struck down.
Requirements
Build a process to receive, log and act on GGL payment-blocking orders
Train treasury and risk teams on the statutory basis for compliance
Record every blocked transaction for later enforcement correspondence
Avoid routing German flows through PSPs that have been subject to GGL orders
F
Theme F
Technical standards
GGL's supervisory systems are backed by published Technische Richtlinien. Every licensee operates a Safe-Server, mirrored to the GGL's Auswertesystem, that retains session and transaction data; connects to the central LUGAS Aktivitäts- and Limitdateien for real-time enforcement; and submits every game for accredited lab certification before launch.
3 standards3 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
Going live without a certified Safe-Server connection to the GGL
Failing real-time LUGAS session or limit calls under load
Deploying a game build that has not been certified by an accredited testing lab
Safe-Server and LUGAS technical guidelines 2
TR Safe-Server
Safe-Server Technische Richtlinie
Game DesignPlayer Rights
The Safe-Server TR (currently v1.15, August 2023) specifies the data model, API interfaces, retention requirements and integrity controls for the operator-hosted Safe-Server. The GGL's Auswertesystem polls the Safe-Server to read session, deposit and event data.
Requirements
Host a GGL-certified Safe-Server in a German or EU data centre compliant with the TR
Upgrade the Safe-Server build on each TR revision within the transition window
Expose the mandated endpoints to the GGL Auswertesystem with documented SLAs
Retain session and transaction data for the TR-mandated period
TR LUGAS
LUGAS Technische Richtlinie
Game DesignRG Critical
The LUGAS TR specifies the real-time integration with the Aktivitätsdatei and Limitdatei — session-token exchange, deposit-registration protocol, error handling and failover. The GGL runs a test system that licensees must integrate against before production go-live.
Requirements
Integrate against the GGL LUGAS test system before production cut-over
Handle Limitdatei and Aktivitätsdatei failure responses as a hard deny, not a silent pass
Log every LUGAS call with correlation-IDs for GGL reconciliation
Run regression against each LUGAS TR version update
Accredited testing-lab certification 1
Cert
Every German game build must be lab-certified
Game Design
Virtual slots and online poker builds intended for the German market must be certified by an accredited testing laboratory (such as GLI, iTech Labs or BMM) before launch. The certification demonstrates compliance with the §22a and §22b mechanic caps and RNG integrity standards.
Requirements
Supply a German-market-specific build to the testing lab for every title
Retain the lab report for the life of the title plus the statutory retention period
Re-certify the title after any material game-engine or mechanic change
Track the accredited-lab list published by the GGL
G
Theme G
Taxation
Germany taxes online gambling at the point of stake. Virtual slots and online poker are taxed at 5.3% of turnover under the Rennwett- und Lotteriegesetz; sports betting is taxed at the same 5.3% rate on stakes. The turnover basis is unusual in Europe and is under commercial and political pressure to move to a GGR model, though no bill is yet on the table.
3 standards2 player-flagged
67%
player-flagged
Regulatory risks this theme addresses
Mis-classifying a product between the slot/poker and sports-betting tax bases
Failing to account for tax on bonus-funded or free-bet activity
Ignoring Land-level Spielbankabgabe on online casino table games
Rennwett- und Lotteriegesetz 2
§§ 36, 37
5.3% turnover tax on virtual slots and online poker
Player Rights
Sections 36 and 37 of the Rennwett- und Lotteriegesetz impose a 5.3% turnover tax on virtual slot stakes and online poker rake/stakes. In force since 1 July 2021 as part of the reform package, the turnover basis is unusual in Europe and is under industry pressure to move to a GGR model.
Requirements
Compute and remit 5.3% tax on every German slot spin and poker rake/stake
Include bonus-funded stakes in the taxable base unless explicitly excluded
Model scenarios for a possible future move to a GGR-based tax
Reconcile monthly tax return with the Safe-Server event feed
Sportwettensteuer
5.3% sports-betting stake tax
Player Rights
Sports-betting stakes are taxed at 5.3% under the Rennwett- und Lotteriegesetz. The rate was harmonised with the slot/poker 5.3% rate in 2021 to remove incentives to arbitrage between products.
Requirements
Compute and remit 5.3% on every German sports-betting stake
Treat free-bet and bonus-funded stakes consistently with GGR advice
Keep the monthly stake feed aligned with tax-authority submissions
Monitor for harmonised rate changes during the GlüStV 2026 review
Länder casino levy 1
Spielbankabgabe
Land-level Spielbankabgabe on online casino table games
Online casino table games, where licensed under §22c, are typically subject to the Spielbankabgabe levy of the host Land in lieu of ordinary corporation and VAT treatment. Rates and formulas vary by Land.
Requirements
Identify the Spielbankabgabe rate and base for every Land where you operate online table games
Build the Land-specific tax calculation into the Safe-Server feed
Engage a tax adviser with Länder-specific expertise
Reconcile Spielbankabgabe with the Land finance ministry monthly
H
Theme H
Enforcement against the illegal market
GGL's enforcement posture shifted in 2025 after the Federal Administrative Court struck down the statutory basis for IP blocking. The current workhorse tools are cease-and-desist orders, host-provider takedown orders and payment-blocking, backed by criminal exposure under the Criminal Code. Expect the GlüStV evaluation to restore a workable IP-blocking basis.
4 standards3 player-flagged
75%
player-flagged
Regulatory risks this theme addresses
Assuming the old IP-blocking regime is still operative
Treating GGL enforcement as targeting only offshore operators — advertising and affiliate exposure is also in scope
Overlooking criminal exposure under §§284–287 of the Criminal Code
Cease-and-desist, takedown, criminal exposure 4
§ 9(1)
Cease-and-desist orders (Untersagungsverfügung)
Player Rights
Section 9(1) gives the GGL broad powers to issue cease-and-desist orders against unlicensed operators. Fines reach €500,000 per infringement, and repeated breaches are escalated through administrative and criminal channels.
Requirements
Triage any GGL correspondence within 48 hours
Retain counsel on retainer with a GlüStV enforcement specialisation
Document remediation steps against each cited infringement
Preserve evidence that may support an appeal to the competent Verwaltungsgericht
Takedown
Host-provider takedown orders
Affiliate Rules
With IP-blocking struck down, the GGL has shifted its primary enforcement posture to host-provider takedown orders. Over 930 domains have been made inaccessible through this route since the shift, and takedown orders now arrive weekly.
Requirements
Maintain hosting relationships with EU providers willing to co-operate with GGL takedown orders
Build a redundancy plan for hosting transitions under takedown pressure
Monitor the GGL monthly takedown statistics in compliance risk reports
Do not promote or partner with operators currently on the takedown register
§ 9(1) no. 5
IP blocking — struck down in March 2025, legislative fix pending
On 19 March 2025 the Federal Administrative Court (BVerwG) ruled that the IP-blocking basis in §9(1) no. 5 GlüStV was incompatible with the Telemedia Act. Existing IP-blocking orders were voided. A legislative fix is expected in the 2026 GlüStV review.
Requirements
Assume IP-blocking is not an available tool against competitor or affiliate black-market content
Re-plan enforcement and anti-counterfeit strategy around takedown and payment-blocking
Monitor the GlüStV 2026 review for a restored IP-blocking basis
Reassess hosting and CDN choices against post-BVerwG risk
§§ 284–287 StGB
Criminal liability for unlicensed gambling and its advertising
Affiliate Rules
Sections 284 to 287 of the German Criminal Code make it a criminal offence to organise or advertise gambling without a licence, with custodial exposure of up to five years. The provisions apply equally to directors and senior managers of the liable legal person.
Requirements
Brief directors and senior managers on personal criminal exposure under §§284–287
Include whitelist and licensing due-diligence in M&A diligence playbooks
Require affiliate partners to warrant compliance with the Criminal Code provisions
Train customer-facing staff to escalate any reference to unlicensed gambling
I
Theme I
Market context & 2026 review
Germany's regulated channel is material but not dominant. Independent estimates in 2024–2025 put channelisation at around 50–77% depending on vertical and source, with roughly €500m in losses migrating to unlicensed sites annually. The GlüStV 2026 evaluation is expected to address the channelisation gap, the deposit cap, advertising scope and the broken IP-blocking basis.
1 standard1 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
Planning on static rules through 2026 — substantial amendments are likely
Under-investing in the legal channel while black-market leakage persists
Assuming marketing or bet-type constraints will loosen without evidence
Evaluation and reform watch 1
Review
GlüStV 2026 evaluation watch list
Player Rights
The GlüStV evaluation report due end-2026 is expected to examine: overall channelisation versus the black market, the €1,000 deposit cap and uplift mechanism, the LUGAS parallel-play rule, the advertising framework including sports sponsorship, restoration of an IP-blocking legal basis, and the Ereignis- und Wettarten-Katalog for live betting.
Requirements
Build a GlüStV review watch list into the legal and product horizon scan
Assign an internal owner for each expected amendment area
Maintain a public-comment position where the operator wishes to influence outcomes
Model commercial scenarios for three outcome clusters: status quo, moderate liberalisation, further tightening