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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.

41 Standards
168 Requirements
38 Player-flagged
5 Categories
Showing all 41 standards
A
Theme A

Federal framework & regulator

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 standards 3 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
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  • Build product and compliance roadmaps against the consolidated GlüStV text, not superseded state regimes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
§§ 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 standards 7 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
§ 22a

Virtual slot machine licence and product scope

Game Design Player Rights

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 Design RG Critical Player 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
§ 22b

Online poker: player-vs-player only, four-table cap, random seat allocation

Game Design RG Critical Player 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
§ 21

Sports betting licence and event-catalogue discipline

Game Design Player 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 Design RG 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
§ 22c

Online casino table games — state-by-state licensing

Player Rights Game 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 standards 9 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
§§ 8, 8a–8d

OASIS: the cross-operator exclusion register

RG Critical Player 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 Critical Player 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
§ 6h

LUGAS Aktivitätsdatei — no parallel play across operators

RG Critical Player 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 Critical Player 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 Critical Game 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
§ 4(5)

Full KYC before play — 18+, OASIS, identity proof

RG Critical Player 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 Critical Player 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 Rights RG 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 standards 7 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
§ 5(1)

The 9pm to 6am broadcast window for slots, poker and casino

Bonus & Ads Player 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 & Ads Affiliate 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 & Ads Affiliate 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
Minors

Advertising must not target or appeal to minors

RG Critical Bonus & Ads Affiliate 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 & Ads Player 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 Rules Bonus & 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 standards 3 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
§ 6d

Permitted payment methods for GGL-licensed sites

RG Critical Player 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 Critical Player 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
§ 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 standards 3 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
TR Safe-Server

Safe-Server Technische Richtlinie

Game Design Player 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 Design RG 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
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 standards 2 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
§§ 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
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 standards 3 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
§ 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 standard 1 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
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