The German online gambling industry may soon experience significant regulatory reforms. The German Online Casino Association (DOCV) and local gambling lawyer Michelle Hembury pointed out in a recent online seminar on the update of the "Interstate Gambling Treaty" that several key policies might be adjusted in the new round of revisions, including clarifications on sensitive issues such as deposit limits, betting restrictions, and IP blocking.
The Joint Gambling Regulatory Authority of the German states (GGL) is currently conducting a mid-term review of the "Interstate Gambling Treaty" that took effect in 2021. This assessment, which began in December 2023, aims to evaluate the effectiveness of current regulations and provide recommendations for the revisions set to start later this year. There is widespread concern within the industry that the upcoming revisions could fundamentally change some of the widely criticized issues in the current regulatory framework.
Currently, Germany has set a maximum limit of 1 euro per bet for online slot machines, and a monthly deposit cap of 1,000 euros for players, which must be tracked nationally through the LUGAS monitoring system. These restrictions are intended to curb gambling addiction issues but have also been criticized as overly strict, indirectly promoting the expansion of black market platforms.
Simon Priglinger-Simader, Vice President of the German Chamber of Commerce, stated at the meeting that the GGL is currently re-evaluating these limits, with adjustments expected no earlier than 2026. He revealed that regulators are trying to redefine the core concept of "affordability," which is a prerequisite for key measures such as raising deposit limits. "We hope to establish a sustainable regulatory model that provides long-term planning and certainty for the industry," he said.
Hembury further pointed out that although the current regulations mention "financial capability" as the basis for players to apply for higher limits, there has never been a formal definition, leading to unclear enforcement standards. A dedicated working group has already begun discussing the details this year, with clearer guidelines expected to be issued in the third or fourth quarter.
The issue of betting limits on online slot machines was also a focal point of the seminar. Priglinger-Simader mentioned that the GGL will discuss at a management committee meeting scheduled for September or October this year whether operators are eligible to apply for higher betting limits. He admitted that the GGL itself does not have decision-making power, and the final decision will depend on the collective decision of the state-level management committees.
In response to industry calls, Hembury suggested that regulatory authorities could consider allowing operators to apply individually for higher single-bet limits, to highlight the flexible needs of different operating environments and push the decision-making process towards a more realistic direction.
Additionally, IP blocking as a technical measure to restrict black market gambling platforms is also a focus of the reform. Although the German Administrative Court previously ruled that the GGL lacks the legal basis to implement IP blocking under the current terms, Hembury believes that the updated treaty will include relevant regulations, enabling this measure to be enforceable.
"This is the first major revision since the treaty was implemented in 2021. We look forward to the GGL coordinating with state representatives and management committees to develop a new plan that balances regulatory effectiveness with industry competitiveness," she concluded.
This reform of the "Interstate Gambling Treaty" is at a critical stage of policy negotiation. The future development direction of the German gambling industry will gradually become clear in this revision.
