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Germany raises online slot stake limits, operators to track player behaviours following change

| By Imogen Goodman | Reading Time: 3 minutes
In the lead-up to the review of the 2021 Interstate Treaty on Gambling, German regulators have lifted the tight cap on stakes for online slots. Will deposit limits and channelisation also be addressed?
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Heeding the calls of the industry, Germany’s gambling authority has agreed to lift the highly debated €1 staking limit for online slot games.  

Starting this July, licensed operators of online slots can increase their stakes above the long-standing €1-per-spin limit. While the €1 cap remains the legal default, operators approved by theJoint Gambling Authority of the Federal States (GGL) can now opt to raise their stakes to either €3 or €5 per spin. 

These higher limits can only be implemented for qualifying players, however. To be eligible for stakes of up to €3, players must be at least 21 years old. To access the €5 limit, meanwhile, they must have shown no signs of “problematic” gambling in the past 90 days.  

Operators are required to carry out special monitoring to track player behaviour both before and after the increase. If indicators of harmful gambling emerge, operators must intervene with appropriate measures. These could include contacting the player, restricting their gambling activity or suspending their account.  

The GGL says the changes are intended to reflect changing market conditions while supporting the objectives of Germany’s State Treaty on Gambling (GlüStV). In particular, the authority points to the treaty’s aims of “maintaining a high level of player protection within a regulated gambling market” and of preventing addiction.   

But operators say the increase in stakes is a tacit acknowledgement that Germany’s online casino regulation has failed to channel players into the legal market.   

‘Positive signal

Following years of industry campaigns, online operators in Germany have responded with enthusiasm to the change, with Entain describing the change as a “positive signal” for Germany’s licensed market. 

“The federal states are demonstrating their willingness to regularly review the practical impact of existing regulations and to make adjustments where necessary to achieve the objectives of the Interstate Treaty on Gambling,” says Simon Priglinger-Simader, senior regulatory affairs manager DACH at Entain Group and vice president of the German Online Casino Association (DOCV). 

“We hope that this decision will encourage more players to return to the regulated market.” 

Under the Interstate Treaty, the GGL has the power to raise staking limits in response to changes in the market. However, the decision needed to be approved by representatives of the 16 federal states who sit on the authority’s administrative board. 

In Priglinger-Simader’s view, the move reflects a growing realisation that the regulated industry is struggling to compete with the black market.  

“It’s clear that the states wouldn’t have made this change if they hadn’t seen the issue with channelisation and with the limited products we have been offering,” he tells iGB.  

Review of the Interstate Treaty  

The decision lands ahead of the hotly anticipated review of the Interstate Treaty, which is set to be finalised by the end of the year. 

Carried out by representatives from Germany’s 16 federal states, it will be the first time the legislation has come under the microscope since entering into force in 2021. The aim is to assess whether the treaty has met key objectives such as channelling players into the legal market and preventing problem gambling.  

For the industry, the answer to these questions is clear. For several years, the legal market has been arguing that over-restrictive regulations, high taxes and slow approval processes have left them unable to compete with the black market.  

The result, according to the DOCV, is an online channelisation rate “in the mid-double-digits”. This is ultimately bad for player protection, they argue.  

Although major structural changes aren’t expected in the review, there are signs that some ideas are cutting through. Most significantly, lawmakers appear to be taking the task of creating an attractive legal market more seriously.  

This is the view of the German Sports Betting Association (DSWV), who told iGB in March that the review had prompted substantive debates on the Interstate Treaty.  

‘Ineffective rules should be removed

“What has changed is a growing awareness that the current framework is not fully achieving one of its central objectives: creating a sufficiently attractive legal market,” Luka Andric, managing director of the DSWV, told iGB. “Only a competitive legal market can keep players in a regulated environment and ensure effective protection.” 

Andric believes the review should result in concrete steps such as the increase in stake limits.   

“Rules that have proven ineffective – particularly in terms of channelisation – need to be revised or removed,” he said.  

However, Priglinger-Simader believes the review could paint a mixed picture. That’s because each of the 16 states are responsible for assessing different aspects of the law.  

“Of course, there are states we will never hear anything positive from,” he says. “That’s fact. But there are some topics where we have more positive expectations.” 

One of these is online table games, which are currently not permitted but could be reviewed by a relatively pro-gambling state. Another is the five-second spin rule for online slots, which the GGL could have leeway to soften.  

According to the Interstate Treaty, games are required to have an “average” spin speed of five seconds, meaning that shorter spins and longer spins could potentially be combined over a longer period of play. The DOCV is currently in discussions with the authority about offering operators this scope.   

Deposit limits  

Another open question is how the rules on deposit limits will be amended after the current guidance expires at the end of the year. 

Currently, player deposits are generally capped at €1,000 per month, although this can be raised to €10,000 or €30,000 per month for a small number of customers who pass screening and risk assessments.  

With two previous amendments unable to gain majority approval from the states, an expected third draft could strike a middle ground, allowing higher limits but with more extensive credit and income checks.  

A “worse-case scenario”, says Priglinger-Simader, would be a return to a blanket cap of €1,000.  

For now, however, the legal market is celebrating its latest win. According to the DOCV, most operators in the market have already started increasing their limits and implementing the necessary player tracking to ensure that customers stay safe. 

Whether the decision proves to be an isolated concession or the beginning of a regulatory rethink will become clearer once the review is published. 

According to Priglinger-Simader, “similar measures will also be needed in other areas” if Germany is serious about boosting channelisation rates in the long term.   

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