The new resource provides clarity and explains legal definitions. It also highlights the differences between online casino games and digital slot games. Furthermore, the regulator has provided a list of all licensed online casinos operating in Germany.

GGL: Online Casino vs. Virtual Slots: What’s the Difference?

The FAQ page notes that many people interpret the term “online casino” as a virtual representation of games typically found in arcades. 

However, the 2021 State Treaty on Gambling (GlüStV 2021) defines online casino games as “virtual replicas of banker games and live broadcasts of a terrestrial banker game with the option to participate via the internet.”

Banker games are typical table casino games such as blackjack, roulette, and baccarat. In Germany, these games can be offered under special conditions and with a state-specific permit.

GGL emphasizes that “online casino” does not include virtual slot games. Legally, they are distinct entities. According to the website:

• Online casino games include table games such as roulette, blackjack, and baccarat. The respective federal states are responsible for licensing and supervision.
• Virtual slot games are digital replicas of slot machines found in arcades and restaurants. GGL oversees virtual slots, issuing the licenses and ensuring compliance.

The FAQ page provides a link to the list of all licensed land-based and online gambling operators. The public can see their physical locations and the dates when licenses were issued.

GGL Warns Against Illegal Platforms Posing as Legal

The regulator also warns of illegal gambling websites posing as legal. GGL warns that many offshore operators use misleading tactics, such as using SEO-driven terms to attract users through Google. 

Illegal platforms also have professionally designed websites to mimic legal offerings. They often advertise free bonuses or free spins and use terms like “exclusive,” “reputable,” or “top game selection.”

The GGL advises consumers to verify whether a platform is legal in Germany before using it. They can do so by checking the safelist on the FAQ page. Additionally, they can refer to another FAQ page specifically designed to identify and address illegal operators.

The Ongoing Threat of Illegal Gambling in Germany

Last year, a GGL report determined that illegal gambling revenue equaled up to 4% of Germany’s total gross gaming revenue in 2023. The regulator estimates that illicit operators generated between €400 million and €600 million ($453 million to $680 million).

Meanwhile, 2023 data from Nielsen Media, which includes Germany’s market research panels, revealed that only about half (50.7%) of German gamblers engaged with licensed providers.

In response, the new German government has pledged to tackle illegal gambling as part of its coalition agreement, signed on April 9.

The German Sports Betting Association (DSWV) welcomed the news. While it describes the proposals as vague, DSWV labeled them as an important signal. The association also proposed five measures to combat illegal gambling:

• Strengthening the competitiveness of legal gambling providers to compete with illegal ones.
• Establishing a nationwide specialized public prosecutor’s office.
• Take a “follow the money” approach.
• Making advertising platforms and affiliate networks more accountable.
• Harmonize European regulations.

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The incoming government set a series of ambitious goals, outlined in the coalition agreement penned on 9 April. The 146-page document covers several issues: the economy, industry, jobs, transport and infrastructure, education, innovation, research, and healthcare.

It also proposes taking more decisive action against illegal gambling. While the passage touching upon the issue was described as “vague” in terms of formulation, the DSWV is still pleased to see that it is under consideration.

In response, the Association has submitted its own concrete proposals for action, detailing how to improve enforcement at the top level, alongside the federal states.

DSWV Proposes Five Measures to Curb Unregulated Operators

The German Sports Betting Association proposes five measures against illegal gambling. 

The first is strengthening the competitiveness of legal gambling providers in order to compete with illegal ones. The premise is to allow legal providers to offer sufficiently attractive products, so German customers need not seek unregulated alternatives. 

The second proposed measure is establishing a nationwide specialized public prosecutor’s office. The proposed office would be a special investigative authority with time and resources dedicated to tackling illegal online gambling. The DSWV believes this is crucial, as legal proceedings have failed due to jurisdictional issues.

Thirdly, the DSWV recommends the “follow the money” approach. This aims to track money flows, including crypto and fiat, to help identify and potentially locate bad actors.

The DSWV also believes that bad actors’ tools—particularly advertising platforms and affiliate networks—must be made more accountable. The hope is that these companies will put greater effort into preventing illegal operators from using their platforms if they themselves may be penalized for doing so.

Finally, the DSWV suggests harmonizing European regulation. With each EU member country having its own laws, enforcing them on an international level is difficult. The Association believes that Germany should push for uniform standards at the EU level, unlocking cross-border enforcement opportunities. 

New Government Must Take Action

While the new government has shown that it is ready to take responsibility, the DSWV has urged it to take further action and translate its coalition agreement into a concrete action plan. 

It believes that federal states should try to strengthen legal gambling by reducing the accompanying bureaucracy, making a more competitive tax framework, and allowing legal gambling providers to become more visible.

The DSWV has encouraged the government to enter dialogue with federal states and legal gambling providers to make the gambling market in Germany fair and safe, as it believes this is the most effective method of curbing illegal gambling.

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Earlier this week, the German legislature agreed to maintain a 5.3 per cent wagering tax on online casino and poker verticals. 

However, the DSWV had recently called for the tax charge to be excluded from legislation, having argued that the German Lander should work together to establish a fair market tax plan.

“Unlike all European countries, Germany does not tax the provider’s earnings for virtual slot machine games and online poker, but rather the individual stakes made by consumers,” the statement from the DSWV read. “This makes the games more expensive for the customers and the winnings less often.” 

DSWV President Mathias Dahms remarked that in its unchanged state, the GlüNeuRStv would not be fit for purpose, stressing his belief that the Bundesrat had ‘jeopardised the success of the new gambling regulation in Germany a few days before it comes into force’.

Dahms added: “There are two alternatives for German consumers: Either they accept that the game will be significantly more expensive for them or they switch to black market offers that are easily available on the Internet and that do not pay taxes in Germany… Neither option is wanted.”

Following the launch of the GlüNeuRStv, DSWV warned German ministers that the regime will fail to even secure a 50 per cent channelisation rate.

Dahms concluded: “For years, the countries had struggled to find a compromise on the State Treaty on Gambling and to open up the online gambling markets in order to finally get this area under regulatory control. 

“Now the countries are destroying their own work with an over-tax regime for virtual machine games and online poker in the last meters.”

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In a statement, Nigel Birrell, CEO of Lottoland, said: “We are disappointed with the result of today’s General Meeting.

“With resolution number two [waiving the requirement on Günther Group to make a takeover offer for Zeal] turning out to be very close with only 51 per cent votes in favour and 49 per cent voting against, we do not believe the outcome provides a clear mandate from the shareholders of Zeal to take the transaction forward,” said Birrell.

“Especially given the fact that without the votes of the Lotto24 shareholders this would not have been approved.”

Birrell stressed that Lottoland stands by the reservations it has about the deal, set out in a number of open letters and statements in the last fortnight.

“This highlights what we have expressed all along,” said the CEO, “that the Lotto24 shareholders are the only ones that will benefit from this transaction; and that the transaction is value destroying for Zeal shareholders.”

However, seemingly acknowledging that the matter is now closed, Birrell said that Lottoland would “continue to look at other M&A opportunities and to consolidate our market leading position in the lotto space.”

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Providing this overview of the new gambling legislations, Slotegrator’s Ayvar Gabidullin noted that the company’s legal department and sales team will be offering advice on German regulations while also assisting with the acquisition of the necessary licences. 

In an article for Slotegrator, he said: “The upcoming online casino regulations in Germany will be a sea change for the country’s gambling industry, bringing a massive new opportunity for both start-ups and established companies who want to expand into Europe’s biggest economy. 

“The latest version of the German Interstate Treaty on Gambling, which will come into force on July 1, 2021, will allow licenses to offer online casino games across the entire country for the first time. 

“If you’re looking to start an online casino or create an online betting site facing the German market but don’t know where to start, Slotegrator has everything you need to get going.

“Among the opportunities for your business is a turnkey platform that has all features operators need for a successful start or a white label casino that not only provides a technical framework but also comes with every tool needed for compliance.”

Gabidullin also explained that iGaming operators can benefit from consultations provided by Slotegrator’s legal team which “can advise potential operators on updates in German regulation and help them deal with a German licence to be able to offer their services in a country”.

He added: “Make sure your business is developing in the right direction and expanding to the regions where the iGaming sector is promising and profitable. Germany has just become one of them, so strike while the iron is hot.”

To read Slotegrator’s guide on Germany’s new online gambling laws, click HERE.

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Last week saw The Sword and The Grail make an early climb into the SlotRank leaderboard, peaking at no.4 as the game continues to slug it out with classic names such as Play’n Go’s Book of Dead and Big Time Gaming’s Bonanza.

The positions in the SlotRank leaderboard are calculated on a daily basis by scanning the lobby positions of hundreds of online slot titles across hundreds of online casinos in a wide range of markets.

The table above has shown that despite only being released a few weeks ago, the slot has made an early entry into Germany’s top 5. The Arthurian-focused slot draws upon the legend of King Arthur, and so it will be interesting to see whether its early surge in popularity will continue in the weeks to come.

It does tend to be a feature of the SlotRank leaderboard, however, that many of the older classic games such as NetEnt’s Starburst or Bonanza tend to maintain their fixtures in casino lobbies.

Taking Bonanza as an example, one of the most recent releases in the top five – albeit still launched three years ago, back in 2016 – has consistently maintained a spot in the top five in Germany, and appears to be striking the right balance with players; so the new slot has a lot of work to do to stay in the top five.

Elsewhere in the leaderboard in Germany, NetEnt continues to dominate the pole position on the leaderboard, with its 2012 release Starburst yet to be toppled from no. 1.

Gonzo’s Quest has dropped slightly to no.5, while Pragmatic Play’s Wolf Gold has just missed out on a top-five position. Tiki Vikings from JustForTheWin has made a jump up to no.8, while Big Time Gaming’s Extra Chilli rounds off the table at no.12.

CasinoBeats‘ weekly SlotRank report is delivered in collaboration with SlotCatalog

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The letter, published on Monday and addressed to Dr Helmut Becker and Jonas Matsson, respectively CEO and CFO of Zeal, sees Birrell question the value of the deal; seek more clarity on cost benefit and even goes so far as to infer a conflict of interests, naming Zeal shareholders Gunther Group and Oliver Jaster.

Indeed, Birrell accuses the Zeal board of acting “in the interest of certain shareholders”.

Birrell said the merger, which was approved by the German Federal Cartel Office on December 18, would lead to “value destruction” if shareholders do not “stop the transaction now.” The deal is currently set to be voted upon at the forthcoming Zeal Extraordinary General Meeting, scheduled for January 18, and Birrell called for this to be delayed.

He listed a number of questions, the answers to which he asserted should be provided in the interests of “all shareholders”. The relevant extract is below.

The two-page letter drew to a close with Birrell stating that Lottoland would make an “alternative offer” for “certain assets” of Zeal Network. The CEO said that Lottoland would shortly contact Zeal with details of the alternative transaction, with a view to publishing the offer by January 31.

Birrell said the alternative offer from Lottoland, which has undertaken its own “outside-in due diligence” on the original deal, would result in a “better outcome for all shareholders”.

Update: Read Zeal Network’s response here

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GGL Chairman Ronald Benter has held meetings with Konrad Landgraf, Managing Director of the State Office for Gambling Addiction in Bavaria (LSG), to strengthen the efforts and begin a new strategy when it comes to social responsibility.

Benter underlined his motive to have discussions with each state authority to improve cooperation and exchange ideas on strengthening the laws of the Fourth Interstate Treaty on Gambling (GlüStV) to combat gambling addiction.

The GGL aims to “better understand the challenges state coordination offices face and develop joint approaches for intensified cooperation” through these individual meetings.

It follows the GGL’s leadership pinpointing challenges during its first meeting of interstate authorities in Halle in January 2023, shortly after the Saxony-Anhalt agency took on the role of Federal Authority for German Gambling.

Benter stated: “It is crucial for us to hear the perspectives of all relevant interest groups and to get a comprehensive picture of the situation. Player protection and raising public awareness are high priorities for us. Through thematic exchange with the state coordination offices, we are further expanding our expertise.”

The GGL has prioritised feedback from state offices focused on healthcare and public welfare, which provide prevention and counselling for gambling addiction. These offices are key stakeholders in the reform of GlüStV.

In 2026, the GGL will present its ‘comprehensive evaluation’ of German gambling to the Bundestag. This study will detail how German gambling has changed since the introduction of the GlüStV laws in 2021.

The evaluation will include the GGL’s recommendations on new federal protections related to gambling advertisements, which require authorisation from the Bundestag.

On the issue of problem gambling, the GGL supported research by the Institute of Public Health at the University of Bremen. The University’s 2023 study showed a steady 2.4% rate of gambling disorders among 18-to-70-year-olds since 2021.

However, independent observers have directly taken aim at the GGL-commissioned studies. They argue that the GGL has supported estimates from gambling studies that fail to consider the high exposure of German consumers to black-market gambling activities, with unlicensed websites reportedly targeting up to 50% of national consumers.

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In collaboration with the agency &US, the marketing campaign will be visible across TV, streaming and digital advertising spaces and is scheduled to run for several months.

StarGames describes the campaign’s TV commercial as showing “slot enthusiasts’ quest for the perfect win line into various life situations”, demonstrating “the love of the game, the willingness to take risks and the chance to experience winning moments without the illusion of quickly making a lot of money”. 

László Pados, Brand Manager of StarGames, stated: “We are aware that gambling is a topic that some people prefer not to discuss. That’s why, as a leading German igaming brand, we feel responsible for addressing all aspects of this form of entertainment more openly. 

“With ‘Let’s Be Honest!’, we also want to emphasise that our company philosophy is clearly aligned with the guidelines of the 2021 State Treaty on Gambling – enabling us to offer top-class entertainment in a protected environment and contribute to curbing the black market.”

StarGames noted that &US played a leading role in developing the TV commercial as well as repositioning its igaming brand.

“We are very pleased with how the collaboration with &US has evolved – from the unique campaign concept to the final TV spot,” commented Gaelle Peleus, Marketing Manager of StarGames.

“’Let’s Be Honest!’ stands out from more common themes in gambling advertising and is a significant step to help our brand gain more visibility nationwide.”

Sebastian Strobel, Managing Partner of &US, added: “Let’s be honest, working with StarGames has been a lot of fun, from developing the new positioning to implementation. This is also reflected in the new campaign.”

Earlier this month, StarGames formed a new collaboration with German Bundesliga football club Borussia Dortmund.

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Tapping into another corner of the German market, the deal will see a selection of Swintt’s slot content taken live on the operator’s igaming service, including titles in the SwinttPremium range. 

Claiming to have proven popularity in the German market, the SwinttPremium range offers a collection of classically-themed slot titles to appeal to traditional slot fans. 

Games in the SwinttPremium range include Seven Seven Pots and Pearls and Extra Win X. 

Lars Kollind, Head of Business Development at Swintt, commented: “Swintt – and in particular, the studio’s SwinttPremium catalogue of games – is already very popular in Germany, so we’re thrilled to have the opportunity to connect with new audiences via Jackpotpiraten.de. 

“We’re sure the collaboration will be a big success and we can’t wait to see how our slots perform with players.”

The deal will also include titles from Swintt’s recently-launched studio subsidiary, Elysium Studios. This will see Jackpotpiraten.de players able to spin the reels on slots such as Elysium VIP and Law of Gilgamesh. 

Florian Werner, Managing Director at Jackpotpiraten.de, added: “At Jackpotpiraten.de, we’ve worked hard to compile a great selection of games from some of the most dynamic software providers in the industry. 

“Being able to now add an award-winning studio like Swintt to our roster will only strengthen this line-up further and we’re sure our players will love seeing what they have to offer.”

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