GGL board to revisit deposit-limit rules at 18 November meeting

The supervisory board of Germany's Gemeinsame Glücksspielbehörde der Länder (GGL) is due to meet on 18 November to try to agree a replacement for deposit-limit rules that lapse at the end of the year, according to discussion at a Gaming in Germany webinar on 21 October. The board has so far been unable to reach agreement, the webinar heard.

The Glücksspielstaatsvertrag sets a cross-provider deposit limit of €1,000 per player per month. Under the current rules, that limit can be raised to €10,000 or €30,000 where certain conditions are met. The arrangement expires at the end of the year.

Dr. Jörg Hofmann of Melchers Rechtsanwälte said the existing "Schufa G" procedure for assessing players' financial capacity is heavily criticised and will in all likelihood be replaced. Open banking solutions such as Kontoblick, or conventional income and asset evidence, are being discussed as alternatives, he said.

Hofmann said a renewed rule on limit increases is necessary. Otherwise, he said, players with previously raised limits could fall back to the regular €1,000 at the turn of the year, which he said could have a marked effect on channelling by pushing players towards unregulated providers.

The webinar also addressed a decision by the Verwaltungsgericht Halle (7 B 491/25 HAL), which found that the GGL has a significant enforcement deficit, according to the discussion. Hofmann said the ruling's possible significance extends beyond the deposit-limit dispute and could carry EU-law consequences, including for freedom to provide services and the coherence of national gambling regulation. The VG Halle has announced a referral to the Court of Justice of the European Union, and Hofmann said the GGL could be placed in a "lame duck" situation that would benefit the black market. The proceedings were initiated by an unlicensed provider.

Christian Heins, co-founder of the European Gambling Gathering (EGG), presented the initiative, which aims to supply data and background information to policymakers, regulators, gambling providers and media, with a focus on investigating and disclosing the activities of illegal providers. Heins said the organisation had analysed advertising registers on social media platforms for advertising by black-market operators and had raised concrete findings with Google, leading to improvements. He said the work would now be extended from Germany to the European level, citing crypto casinos as a current issue.

On sports betting, Dr. Nepomuk Nothelfer of Melchers said bets on esports events are currently considered non-approvable, a blanket rejection he considers legally unconvincing. He said he and colleagues identified nine esports disciplines that could in principle qualify, and that three of them are the focus of a new approval procedure. The GGL has requested further information but has not rejected the application outright, which Nothelfer described as a positive sign. Whether the authority will ultimately approve the application and open esports as a new bettable category is not yet established.

Gaming in Germany said an update on these topics is due at its conference on 10 November in Berlin.