Germany: GGL Considers Higher Slot Stakes and Deposit Reforms

Germany is now considering updates to its gambling laws that could change how online stakes and deposits are regulated. Industry experts believe that revisions to the current system may help legal operators better compete with illegal markets and clarify ongoing regulatory confusion.

Good to know

• Germany enforces a €1 stake cap on online slots and a €1,000 monthly deposit limit across all platforms.
• A federal working group is expected to clarify “affordability” rules by late 2025.
• The GGL may include changes to allow higher slot stakes under certain conditions.

During a recent webinar, DOCV Vice President Simon Priglinger-Simader suggested that the Gemeinsame Glücksspielbehörde der Länder (GGL) may soon change rules on deposit and stake limits. These adjustments are part of an ongoing review of Germany’s 2021 Interstate Treaty on Gambling.

An interim evaluation launched in late 2023 set the stage for these changes. According to Priglinger-Simader, the existing rules are likely to be replaced before 2026. One of the key issues is how the law defines “affordability,” a term used to determine whether a player can request higher deposit limits.

Industry lawyer Hembury explained that “economic capacity” has been referenced but not clearly defined in current legal documents. She said, “It’s only a term that has been picked up in the explanatory notes,” and added that there is hope a practical definition will be included in the upcoming revisions.

Questions Around Stake Increases

Operators are still uncertain whether they can request higher slot stakes under current law. While the €1 per spin limit is in place, Priglinger-Simader stated that the GGL’s administrative board may resolve this issue during its next meetings in September or October.

He added, “The GGL told us several times that they cannot decide, or don’t want to decide on their own,” stressing that the administrative board must make the final call.

Hembury agreed and said one solution could involve operators individually applying for stake increases. She believes such moves might push the board to take action and focus on adjusting outdated rules.

IP Blocking and Legal Gaps

The panel also raised concerns about enforcement. Last year, a court ruled that the GGL lacked a legal foundation to use IP blocking as a tool against unlicensed gambling websites. However, Hembury believes the updated treaty will address this by including new language that provides a legal path for blocking access to illegal operators.

She concluded, “I assume GGL will have to kind of put their heads together with the Administrative Board and all of the representatives of the federal states and amend the interstate treaty.”

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