Revised Agreement within German States May Alleviate Ongoing Disputes over Deposit Caps
In the heart of Europe, Germany is gearing up for significant changes to its gambling landscape, with amendments to the Interstate Treaty on Gambling set to occur this year. The current regulatory framework, established since the 2021 treaty, has been instrumental in shaping the nation's approach to gambling, but challenges remain.
Since the implementation of the treaty, Germany has adopted a national regulatory approach, including a €1 maximum stake limit on online slots and a €1,000 monthly deposit limit across all regulated platforms. The LUGAS system monitors compliance nationally. The Joint Gambling Supervisory Authority (GGL), established in 2022, oversees sports betting and online gambling, ensuring operator licensing, financial audits, player protections, and combating illegal gambling.
Despite these protective measures, licensed operators face a competitive disadvantage compared to black market operators, primarily due to the stringent limits and restrictions, leading to ongoing player migration to unregulated platforms.
An interim evaluation of the Interstate Treaty was launched in December 2023 to assess the effectiveness of the current regulations and propose improvements. Some of these recommendations are expected to be adopted when the federal states amend the law in 2025. The Deutscher Online Casinoverband (DOCV) and legal experts suggest that the updated treaty could specifically address the existing confusion related to IP blocking and the deposit and stake limits, potentially allowing for a more flexible regulatory regime that better balances player protection and market competitiveness.
The GGL's 2024 activity report highlights efforts against illegal gambling, including initiating over 230 prohibition proceedings and geo-blocking more than 650 illegal sites under the Digital Services Act. Payment blocking also impedes illegal deposits and withdrawals, enhancing enforcement effectiveness. Courts in 2024 approved the GGL’s "Markers of Harm" used to monitor increased deposit limits and detect problematic gambling behavior early, setting legal precedent to support uniform player protection standards across Germany.
Industry associations like DSWV have called for urgent reforms to make the licensed market more attractive, recommending easing some restrictions, such as allowing more betting types and live betting options, to counter the structural problems and black market competition.
In conclusion, the Interstate Treaty on Gambling in Germany is under active review in 2025, with expected amendments aimed at resolving deposit/stake limit confusion, refining IP blocking practices, and improving market competitiveness while maintaining strong player protections. The GGL continues to enforce regulations and combat illegal gambling vigorously, supported by recent court decisions. Industry stakeholders remain engaged, pushing for reforms to make the licensed market more appealing and effective against the black market.
Since the amendments to the Interstate Treaty on Gambling in 2025, Germany may consider easing restrictions, such as allowing more sports-betting types and live options, to enhance market competitiveness and reduce the appeal of unregulated sports-betting platforms. The Joint Gambling Supervisory Authority (GGL) has been active in combating illegal sports-betting by geo-blocking over 650 illegal sites and initiating over 230 prohibition proceedings, thus aiming to ensure a fair and safe sports-betting landscape in the nation.
