Germany's gambling market has finally shown some "green shoots" recently. The ongoing review of the "Interstate Gambling Treaty" (GlüStV 2021) requires a comprehensive assessment report to be submitted by December 31, 2026. The core issue of this review is: Have those strict regulations achieved the expected goals? PASA's official website noted that excessive taxation and overly stringent restrictions have pushed many players towards the black market, and policymakers now seem willing to listen to the industry's voice.
Luka Andric, Managing Director of the German Sports Betting Association DSWV, told iGB that this review is turning from a "formality" into a substantive debate—whether the 2021 framework has achieved its core goals in practice. In his view, this should be a real "reality check." "Those rules that have been proven ineffective, especially those affecting channelization, must be amended or repealed."
Rules too strict, taxes too high, players have run away
The ambition of GlüStV 2021 was clear: to establish a unified national framework, strictly protect players, and allow legal operators to compete fairly with the black market. But reality is more complicated than imagined. A series of strict player protection measures—including a maximum single bet of 1 euro on slot machines, a mandatory 5-second spin interval, and a monthly deposit limit of 1000 euros—have made legal products less attractive. Meanwhile, a 5.3% betting tax further compresses the profit margins of operators, making it harder for them to compete with offshore platforms.
As a result, the black market continues to grow. Simon Priglinger-Simader, Vice Chairman of the German Online Casino Association DOCV, believes this reflects a structural problem: "The main lesson is that excessive regulation and over-taxation do not bring good results, but push players towards the black market." Lawyer Michelle Hembury observed that regulators and the industry are "getting closer and starting to talk on an equal footing." This shift is partly the result of legal, practical, and institutional factors.
Is the review expected to be completed on time? Opinions vary
This review covers a wide range, with 16 federal states each responsible for assessing different areas—from licensing, advertising to product rules. Hembury said the states have already taken on different "sponsorship" roles in various areas and are currently "still within the internally set deadlines," with results expected to be announced by the end of 2026. However, many people expect delays. Priglinger-Simader pointed out that discussions among the 16 states are inherently complex, and the assessment report might not come out until 2027.
However, content is more important than time. External expectations for reform are not high. "I don't expect the report to bring major changes or fundamental shifts," Priglinger-Simader said. A more likely outcome is a series of targeted adjustments, rather than a complete redesign. Lawyer Gabriele Stark-Lütke Schwienhorst also agreed, describing the process more as "calibration based on assessment."
What might really change?
While comprehensive reform is unlikely, several key directions have already shown signs. Product regulation is one of them. Online casino games, especially table games, are currently regulated by individual states, and licensed products are still scarce nearly five years after legalization. Priglinger-Simader believes that moving to a unified national framework would be a "significant progress."
Player protection measures are also being reassessed. The long-criticized monthly deposit limit of 1000 euros is starting to loosen—now it can be increased under strict conditions, with a maximum of 30,000 euros in special cases. Stark-Lütke Schwienhorst believes this shows that "narrower adjustments" are possible within the existing framework. Additionally, the betting limits and gameplay restrictions on slot machines might also be early signs of adjustment.
But the thorniest issue is still taxation. The 5.3% betting tax has been widely criticized for undermining competitiveness. Priglinger-Simader bluntly stated: "The number one issue is the betting tax on online slot machines." If changed to a tax model based on total gaming revenue (GGR), legal products would be more competitive. However, the problem is that tax policy is at the federal level, not directly under the jurisdiction of the interstate treaty, requiring a broader political consensus.
What lesson has Germany taught its European neighbors?
Germany's experience is increasingly becoming a reference for surrounding markets. The Netherlands is a clear example—a series of tax increases and stricter restrictions have already put pressure on the legal market. Early signs of revenue decline and channelization concerns, similar to Germany's previous trajectory, are emerging.
Lawyer Chris Elliott pointed out: "Taxation and regulation cannot be considered in isolation." Higher tax burdens have changed the economic model of operators, limiting their ability to offer competitive odds, bonuses, and products. The result is that "consumers will flow to offshore websites not bound by these constraints." More importantly, once channelization is lost, it is difficult to recover.
The UK has also been mentioned. Melanie Ellis of Northbridge Law said: "The lesson for the UK government and the Gambling Commission—although perhaps a bit late—is that players will and indeed do go elsewhere if restrictions are too many and too fast." She emphasized that each measure can be defended individually for player protection, but the cumulative effect instead pushes players (including the most vulnerable groups) into an almost unprotected environment.
Green shoots have appeared, but can they take root?
Germany's regulatory framework is unlikely to undergo dramatic changes. The commitment to player protection still exists, and political constraints also limit the space for reform. But the direction has indeed changed. "If we see changes like an increase in betting limits, that's a clear signal that regulators are listening," Priglinger-Simader said.
Germany's experience shows how easy it is for regulation to deviate from balance, and once lost, how difficult it is to restore. Meaningful changes' "green shoots" have already appeared, but whether they can take root depends on how far policymakers are willing to go. PASA's official website will continue to monitor this process's profound impact on the European gambling regulatory landscape.
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This article is from "PASA-Global iGaming Leaders," a gambling industry news channel:https://t.me/pasa_news
Original deep channel for gambling:https://t.me/gamblingdeep
Free data report: @pasa_research
PASA Matrix: @pasa002_bot
PASA official website: https://www.pasa.news
