Date: 10.03.2025

by Tomasz Jagodziński

Germany’s Gambling Regulations Under Scrutiny

Germany’s Fourth Interstate Treaty on Gambling (GlüNeuRStV) has come under scrutiny following allegations that state governments have permitted online gambling operators to circumvent financial safeguards. An investigative report by Investigate Europe, titled “Legal, illegal, doesn’t it matter?”, claims that state authorities have turned a blind eye to regulatory breaches, allowing gambling firms to operate outside the intended framework.

Disputed Financial Checks and Deposit Limits

Under the GlüNeuRStV, which has been in force since July 1, 2021, licensed operators must enforce a €1,000 cross-operator monthly deposit limit for customers. This restriction can be increased to €10,000 if a customer’s financial standing is verified through official records such as tax documents or other approved sources.

However, Investigate Europe reports that German federal states have allegedly facilitated a way around these restrictions by permitting the use of Schufa-G credit checks, a mechanism that critics argue does not adequately verify financial stability. Through a court settlement reached in November 2022, the Glücksspielbehörde (GGL), Germany’s gambling regulator, was authorized to approve Schufa-G checks as a method for assessing deposit limit increases.

Bundesländer Accused of Regulatory Backdoor

The report suggests that German Bundesländer (federal states) engaged in a “secret agreement” with operators to sidestep more stringent financial assessments. Bremen Senator Ulrich Mäurer strongly criticized the approval of Schufa-G, calling it a “bogus credit check” that fails to ensure proper due diligence on player finances.

Further complicating the issue, the Regional Court of Lüneburg ruled that Schufa-G checks do not meet legal standards for assessing a customer’s economic condition. Critics argue that the regulatory approach has inadvertently exposed vulnerable customers to financial harm, as illustrated by a pending legal case against Tipico, where a customer reportedly lost €30,000 while gambling without proper financial scrutiny.

Calls for Regulatory Intervention

Concerns have been raised over the impact of the regulatory framework, with reports indicating that approximately 300,000 players now have deposit limits exceeding €1,000 per month. Critics warn that the number is likely to grow unless stricter enforcement is introduced. The ongoing dispute also highlights the allowance of live betting services, despite such offerings being explicitly prohibited under the treaty.

The Deutscher Sportwettenverband (DSWV), Germany’s sports betting trade association, refuted claims of regulatory negligence, labeling the investigation an “unfounded scandalisation.” The DSWV argued that details of the regulatory settlement had been publicly disclosed in an interim report by federal states, accessible via the Conference of Interior Ministers’ website.