GGL outlines legal online gambling in Germany

The Gemeinsame Glücksspielbehörde der Länder (GGL), Germany's federal gambling regulator, has issued a comprehensive public clarification addressing the legal definitions and licensing framework for online casinos operating within the country. This move comes in response to a growing volume of public inquiries and increasing confusion over which gambling offerings are legally permissible under German law.

With the online gambling industry in Germany experiencing rapid growth—and in light of ongoing enforcement actions against illegal operators—the GGL has taken the step of publishing a detailed Frequently Asked Questions (FAQ) section. This aims to provide clear, legally grounded answers regarding the distinction between regulated and unregulated online gambling services.

Background: The State Treaty on Gambling

Germany’s regulatory framework for online gambling is governed by the Glücksspielstaatsvertrag 2021 (State Treaty on Gambling 2021), which came into force on 1 July 2021. This treaty represents a landmark effort to unify the country’s gambling laws under a consistent national standard, though responsibility for certain types of gambling remains at the state level.

Under this legal framework, the term “online casino” is narrowly defined and refers only to specific games of chance such as:

• Virtual roulette
• Blackjack
• Baccarat

These games are subject to strict regulation and require a license issued by the relevant state authority—not the GGL. By contrast, the GGL is responsible for the licensing and oversight of virtual slot machine games, which are considered a distinct category of gambling.

Misuse of the term “online casino” by unlicensed operators

A key reason for the GGL’s recent clarification is the ongoing misuse of the term “online casino” by many unauthorized operators. These entities frequently use the label to promote virtual slot games, misleading consumers into believing they are engaging with fully licensed and legal platforms.

This practice not only contravenes legal advertising standards but also creates significant confusion among consumers. Many users are unaware that such platforms may be operating outside the scope of German gambling law, exposing them to substantial risks.

The GGL has reiterated that licensed providers of virtual slot games are explicitly prohibited from using the “online casino” designation in their branding or marketing materials. Any operator found doing so may face regulatory sanctions, including the suspension or revocation of their license.

Legal licensing framework: A state-by-state approach

While the GGL holds authority over virtual slot machine games and sports betting, the licensing of actual “online casinos”—defined as offering table games—is managed independently by individual German states. As of 26 May 2025, only two states have issued such licenses:

• Schleswig-Holstein
• Bavaria

These states have permitted a total of five legal online casino operations. Each operator is subject to state-specific licensing requirements and compliance obligations. Importantly, no license for table games is issued by the GGL itself.

This decentralized approach means that users must exercise diligence in understanding the origin of a gambling platform's license. The regulatory distinction between a GGL-licensed operator and a state-authorized online casino is critical from a legal standpoint.

Consumer risks and potential legal consequences

Engaging with unlicensed or illegal gambling websites carries numerous risks, both financial and legal. The GGL’s FAQ underscores several dangers associated with unauthorized platforms:

• Manipulated or rigged games that operate without fair-play guarantees
• Lack of payout security, potentially leading to forfeiture of winnings
• Inadequate data protection, increasing the risk of identity theft or fraud
• Absence of responsible gambling features, such as deposit limits or self-exclusion tools

Legal liability for users, including possible criminal sanctions depending on the severity and nature of the engagement

The GGL warns that players who knowingly participate in illegal gambling activities may be in violation of German criminal or administrative law. Even where criminal sanctions are unlikely, civil liability or penalties under regulatory frameworks may still apply.

The official whitelist: A tool for consumer protection

To help consumers navigate the legal landscape and avoid falling victim to deceptive operators, the GGL maintains an official whitelist. This public registry contains up-to-date information on:

• Fully licensed gambling operators in Germany
• The specific services they are permitted to offer
• Their licensing authority (GGL or relevant state)

Consumers are strongly encouraged to consult this list before depositing funds or creating accounts on any gambling website. Use of platforms not included on the whitelist is discouraged and may involve serious risks.

The whitelist is accessible via the GGL’s official website and is updated regularly to reflect changes in licensing status or enforcement actions.

Importance of public awareness and legal clarity

The GGL’s new FAQ initiative is part of a broader campaign to increase transparency and public awareness around gambling regulation in Germany. In addition to publishing guidelines, the authority continues to monitor online platforms for violations of advertising rules, unlicensed operations, and other forms of non-compliance.

By clarifying the legal definitions and licensing mechanisms involved in online casino gaming, the GGL aims to promote a safer digital gambling environment for German consumers while curbing the influence of illicit providers.

Ongoing enforcement and international cooperation

Germany’s regulatory efforts are not limited to domestic platforms. Many illegal gambling websites are operated from abroad, often using complex networks to avoid detection and enforcement. To address this challenge, the GGL works in cooperation with international regulatory bodies, law enforcement agencies, and technology providers.

One key area of focus is the blocking of illegal domains, often via DNS measures or through cooperation with internet service providers (ISPs). The GGL also takes action against payment providers that facilitate transactions for illegal gambling platforms.

By employing these measures, the authority hopes to disrupt the financial and technological infrastructure that supports unlawful operations and to encourage legal compliance throughout the industry.

Summary and conclusions

The recent clarification by the GGL is a timely and necessary intervention aimed at reducing confusion in a rapidly evolving digital gambling landscape. As more Germans turn to online gaming options, clear distinctions between legal and illegal operators become ever more important.

Consumers are urged to:

• Understand the legal difference between table games and slot machines
• Verify operator credentials through the official GGL whitelist
• Avoid platforms that misuse the term “online casino”
• Be aware of the personal and legal risks of unlicensed gambling

Ultimately, the GGL's mission is to protect consumers, uphold legal standards, and foster a responsible gambling environment in accordance with the national and state-level legal frameworks.

FAQs

What is the legal definition of an online casino in Germany?
An online casino refers specifically to virtual table games such as blackjack, roulette, and baccarat. These games require a state-level license.

Who issues licenses for online casinos in Germany?
Licenses for online casinos are issued by individual German states, not by the GGL. Only a few states, like Bavaria and Schleswig-Holstein, currently issue such licenses.

Does the GGL issue any gambling licenses?
Yes, the GGL issues licenses for virtual slot machine games and sports betting, but not for table games defined as online casinos.

Why is the term “online casino” often misused?
Unlicensed operators frequently misuse the term to attract players by creating a false impression of legal legitimacy.

How can I verify if a gambling website is legal in Germany?
You can check the GGL’s official whitelist, which lists all licensed operators and the services they are authorized to provide.

What are the risks of using unlicensed gambling websites?
Risks include manipulated games, no payout guarantees, poor data security, lack of responsible gambling tools, and possible legal consequences.

Is it illegal to use unlicensed gambling websites?
It can be. While users may not always face criminal prosecution, participation in illegal gambling may breach administrative laws and carry penalties.

Which German states have issued online casino licenses?
As of May 2025, only Schleswig-Holstein and Bavaria have issued such licenses.

Are virtual slot games considered online casinos under German law?
No, virtual slot games are regulated separately and must not be labeled as online casinos. They fall under the jurisdiction of the GGL.

Can foreign gambling operators legally offer services to Germans?
Only if they are licensed under the German framework. Foreign operators must comply with the State Treaty on Gambling to be lawful in Germany.