GGL reportedly tightens Germany’s deposit-limit checks from 2027

Germany's Gemeinsame Glücksspielbehörde der Länder (GGL) is reported to be replacing its decision guideline under section 6c (1) sentence 3 of the GlüStV 2021 with effect from 1 January 2027, according to information available. Under the reported model, operators granting a monthly deposit limit above €1,000 would have to have income or assets verified. The reported change follows a ruling by the Verwaltungsgericht Halle, which found the SCHUFA-G credit check unsuitable as proof of financial capacity because it only reflects the probability of over-indebtedness, in a decision of 6 August 2026 (7 B 491/25 HAL).

The Oberverwaltungsgericht Sachsen-Anhalt left the question of the applicability of credit checks such as SCHUFA-G expressly open in the GGL's appeal proceedings (3 M 61/26). The reported guideline is based on the principle that a credit check remains mandatory but can only prevent a limit increase, not justify one; proof of financial capacity would rest on income or asset data. Before any deposit limit is set or raised, the reported requirements include that the application comes from the player, that no advertising of higher limits takes place, that the player is at least 21 years old and not blocked, that monitoring data from the preceding 30 days has been assessed and shows no anomalies, that there are no indications under section 8a (1) GlüStV 2021, that a credit check has been carried out beforehand, and that financial capacity has been demonstrated in line with the tier. Self-declarations would not suffice, and the player would declare that the limit is covered by own, non-credit funds and does not endanger due obligations. The limit would be set in LUGAS for a fixed period and become effective after the statutory waiting period of seven days.

The reported model sets out four tiers. For a monthly limit of €1,001 to €3,500, a 70% surcharge applies to the partial amount, requiring capacity of €5,950 at the upper bound, with verification at the latest after 12 months by account information or documents. For €3,501 to €7,000, the surcharge is 50%, requiring €11,200, with half-yearly repetition and the procedure left open, for example account information. For €7,001 to €10,000, the surcharge is 30%, requiring €15,100, with quarterly repetition and the procedure left open. For €10,001 to €30,000, the surcharge is still open, with repetition at least quarterly and a qualified account information procedure mandatory. A requested limit of €5,000 would require proof of free capacity of €8,200 per month. Tier 4 is limited to 1% of an operator's active players, measured on the average of the three preceding calendar months. Income, assets or a combined assessment of both would be admissible as proof, and where demonstrated capacity is insufficient, the player would be offered the highest permissible limit.

Play behaviour would be monitored continuously after a limit is set, with intensity rising by tier. In the event of anomalies, the limit could fall back to €1,000. Every setting would be time-limited, the player would be reminded in time of the repeat check, at which the credit check would be run again, and without a successful repeat the limit would fall back automatically. Significant new indications, such as returned direct debits, unusual deposit patterns or hits in the early warning system, would trigger an immediate review. Each decision would be documented in a reviewable form, including data collected, capacity calculation, tier, expiry date and any reason for refusal.

Increased limits existing on 31 December 2026 would continue until the tier-appropriate repeat check, at the latest three months after the guideline takes effect, probably until 31 March 2027. Existing behaviour data would be credited and no new 30-day waiting period would arise. Operators that do not complete the check in time would see limits fall back to €1,000. The report recommends that operators bring existing customers into the new checks in stages from January.

Several points remain open before the guideline takes effect, according to the report. The surcharge in tier 4 has not been set, and at least the tier 3 rate should be applied until it is clarified. The requirements of the qualified account information procedure for tier 4 are undefined, including the query period, the number of accounts and the depth of analysis, as is which data operators would receive and retain. The report describes the transmission of all account transactions to a gambling platform operator as problematic under data protection law and favours a model in which the operator receives only the result, namely capacity, tier and audit trail, with the account information provider holding the transaction data for official checks; it says the GGL should clarify whether such a result-based proof suffices. It also says the treatment of assets needs explanation, including whether a mortgaged property, a share of company assets or a car can be counted, and that the requirements for credit products by tier and whether sources beyond SCHUFA-G are permitted remain open. Rules are also missing for the self-employed, fluctuating incomes, joint accounts and whether social benefits such as Bürgergeld may count as free capacity.

The report says the new guideline would end a practice that has shaped limit increases in the German market since the sports betting comparison of 2022, moving away from the score towards demonstrated income. It states that operators' technical procedures must be in place by the turn of the year and that existing customers must be checked by the end of March. The report was written by the managing director of insic GmbH, a provider of KYC procedures, financial capacity checks, real-time player monitoring and risk management systems, who also supplies money laundering officers to the gambling industry through GFR-Consult Beratung GmbH; it states that he is not a lawyer and that the article summarises the decisions and does not replace legal advice.