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The Third Interstate Treaty on Gambling (Glücksspielstaatsvertrag 2021, or GlüStV 2021) took effect on 1 July 2021 and, for the first time, allowed nationwide licensing of online sports betting, virtual slot machines and online poker. Since 1 January 2023 these verticals have been licensed and supervised centrally by the Gemeinsame Glücksspielbehörde der Länder (GGL), based in Halle (Saale). Online casino table games such as roulette, blackjack and baccarat are not part of the central regime and remain regulated by the individual federal states (Länder), several of which restrict or monopolise them. A distinctive and frequently misunderstood feature is that virtual slots, online poker and sports betting are taxed on player stakes/turnover rather than on gross gaming revenue.

Two parallel systems

Germany runs two regulatory tracks at once. The GGL centrally licenses online sports betting, virtual slots and online poker for the whole country, but online casino table games such as roulette, blackjack and baccarat sit outside its remit. Each of the sixteen Länder decides separately whether to permit those games, cap the number of licences or reserve them for a state monopoly. For a diligence reader this means a single nationwide slots and poker licence does not extend to table games, and their availability, tax treatment and conditions can differ from one federal state to the next.

The turnover-tax trap

The 5.3 per cent levy is charged on stakes wagered, not on gross gaming revenue, which makes it far heavier than the headline rate suggests. On a slot returning roughly 96 per cent to players, gross win is only about 4 per cent of stakes, so a turnover tax of 5.3 per cent can exceed the entire gross win before any operating cost is met. The burden therefore falls hardest on high-return products, compressing or erasing margin. It is structurally different from the revenue-based gambling taxes used across most other regulated European markets.

Protection built into the product

Germany's player-protection rules are unusually prescriptive and shape the product itself. A 1,000 euro monthly deposit limit applies across all licensed operators, enforced through the central LUGAS activity file so a player cannot reset it by switching sites. Virtual slots carry a 1 euro maximum stake per spin and a minimum spin duration of five seconds, while features such as jackpots, autoplay and parallel play are not permitted. The OASIS register blocks self-excluded and barred players nationwide. The combined effect is a slower, lower-stake slot format markedly distinct from other markets.

The channelisation gap

Channelisation, the share of play reaching licensed sites, remains a persistent concern. The same measures that protect players, the stake cap, slower spins, cross-operator deposit limit and turnover tax, also make the licensed product less competitive against unlicensed sites offering table games, higher stakes and larger jackpots. Published estimates of the legal channel vary widely and are contested, so precise percentages warrant caution, but regulators and operators broadly agree a substantial unlicensed market persists. Closing that gap is a recurring theme in debate over the treaty's scheduled evaluation and reform.

How the GGL enforces

The GGL's enforcement toolkit centres on ordering unlicensed operators to cease, blocking payments to and from them, and requiring hosting providers to remove or restrict access to offending domains. Its power to compel internet access providers to block sites at the network level was curtailed by a March 2025 Federal Administrative Court ruling, which found the treaty lacked a sufficient legal basis for such orders against access providers. The authority has since relied more on host-based and payment-blocking measures, and expanded blocking powers feature prominently in current reform proposals.

Tax

Turnover / stakes (NOT GGR)

5.3% of stakes on virtual slots, online poker and sports betting

Uniform 5.3% stake (turnover) tax since 1 July 2021 under the Race Betting and Lottery Act (Rennwett- und Lotteriegesetz, RennwLottG); raised from the previous 5% sports-betting stake tax. Basis of assessment is the stake less the tax itself. Because it is levied on turnover rather than GGR, the effective burden on operator margin is far higher than a headline revenue rate. Online casino table games are taxed separately under state rules.

Key facts

Licence term5 years (fixed term for online licences)
Regime since2021
Key-person licencesNo separate personal licence, but applicants must prove reliability, expertise and financial capacity; managing directors and beneficial owners undergo suitability/probity checks and the operator must maintain an EU establishment.
Central regulatorGGL (Gemeinsame Glücksspielbehörde der Länder), Halle (Saale)Fully operational for licensing since 1 January 2023
Central verticalsOnline sports betting, virtual slots, online pokerLicensed nationwide by GGL
State-level verticalsOnline casino table games (roulette, blackjack, baccarat)Regulated by the individual Länder; availability varies by state
Player protectionEUR 1,000 cross-operator monthly deposit limit; OASIS national self-exclusion registerPlus EUR 1 stake cap and 5-second minimum spin for virtual slots

RTP rules

Minimum RTP

No statutory minimum RTP for virtual slots (virtuelle Automatenspiele). §22a of the Interstate Treaty on Gambling 2021 (Glücksspielstaatsvertrag) regulates stake, timing and jackpots but sets no payout floor.

Display required

§22a(3) GlüStV requires the player to be shown, where the stake is placed, the probability of winning the top prize and the average payout ratio per €1 staked; the game rules and pay table must be easily accessible and understandable.

Licence types

Online sports betting licence (GGL)Virtual slot machine licence (GGL)Online poker licence (GGL)Online casino table-games licences (issued at the Land/state level)Land-based and lottery licences (state level)

Fees

Security depositMinimum EUR 5 million (can be increased, up to ~EUR 50m)Financial guarantee required of licensees
Ongoing supervisory feeAnnual fee scaled by turnover (roughly 0.06%–0.2%)Charged by the GGL
Licence / application feesTurnover-scaled statutory fee, calculated per licence year on stakes (§ 9a(4) GlüStV 2021): 0.2% up to €40m stakes (min €100), tapering to a marginal 0.06% at the top bandSet by statute, not case-by-case discretion. The widely cited €185,000 is the fixed component of the highest tier only (operators with over €130m in annual stakes: €185,000 + 0.06% of stakes above €130m); smaller operators pay proportionally less. Assessed per year of the licence term, reduced 10% for each subsequent year.

Change-watch

2025-2026

GGL intensified enforcement against unlicensed operators (IP and payment blocking); ongoing industry and political debate over the 5.3% turnover tax and strict deposit/stake limits pushing players toward the illegal market, alongside a scheduled evaluation of the GlüStV 2021 regime.

2026-03-17

GGL set out its position on the 2021 State Treaty evaluation, describing the ~77% online-gambling channelisation rate as scientifically confirmed; the states final evaluation report is expected by end-2026

Not legal or tax advice. This is a teaching summary; confirm every figure against the primary regulator (Gemeinsame Glücksspielbehörde der Länder) before relying on it.