Germany Online Gambling Licence 2026: GGL Whitelist Counted, § 9a Fees, 5.3% Stake Tax and the €5 Slot Limit

The short answer: one regulator for slots, poker and betting, sixteen for roulette

Germany’s online market runs on the Glücksspielstaatsvertrag 2021 (GlüStV 2021), a treaty between the 16 Länder in force since 1 July 2021. Section 4 (4) allows online gambling only for lottery sales and brokerage, sports and horse betting, online casino games, virtual slot games and online poker. Everything else online is prohibited.

The treaty splits those products between two kinds of authority. The Gemeinsame Glücksspielbehörde der Länder (GGL) issues permits for sports betting, online poker and virtual slot games, and for online horse betting under § 27 (2), each “mit Wirkung für alle Länder” (§ 9a (1) no. 3). Online casino games, meaning virtual versions of banked table games and live-streamed tables, belong to the Länder. Under § 22c each Land may run them itself or grant concessions, at most as many as its casino law allowed for land-based casinos on 17 January 2020.

The register shows how that split works out in practice. We read the GGL’s official whitelist (§ 9 (8) GlüStV 2021) on 11 November 2026 and counted each permit entry:

Product	Permits	Companies’ address in Malta	Domains listed	Supervised by
Virtual slot games	36	27	98	GGL
Sports betting	27	24	33	GGL
Online poker	5	5	7	GGL
Online horse betting	5	3	7	GGL
Online B2C, GGL total	73 (50 companies)		125 unique
Lotteries, lottery agents, brokers, social lotteries	56			GGL
All GGL-supervised permits	129
Online casino games (table games)	5	3	8	Schleswig-Holstein (4), Bavaria (1)

The 129 matches the figure the GGL gave in its five-year review of 22 September 2026, so the list we parsed is the same list the regulator counts. That release also gives 229 permitted sites; our parse of the list’s GGL entries returns 221 domain entries and 177 unique domains, so the two counts use different units and the GGL figure is not reproduced exactly.

Three things in that table matter for a market-entry decision. Fewer than six in ten GGL permits are the online B2C products most operators mean when they say “German licence”. The Maltese address dominates: 27 of 36 slot permit holders and 24 of 27 sportsbooks are Maltese companies, which is legal because § 4a (1) no. 3 (b) requires a seat anywhere in the EU or EEA, not in Germany. And concentration is high: one slot licensee, Skill On Net Limited, carries 41 of the 98 slot domains, or 42%.

Seventeen companies hold both a slot and a sports betting permit. Thirty hold a single online B2C permit.

Online roulette is not a GGL product

This is the point most entry guides blur. A GGL slot permit does not cover roulette, blackjack or baccarat in any form. Section 22a (2) bans virtual slot games that correspond to banked table games, and § 22a (11) bans the words “Casino” and “Casinospiele” in the slot offer and its advertising.

Online table games sit under § 22c, and the whitelist on 11 November 2026 listed five entries for them. Four are listed for Schleswig-Holstein under that Land’s authority: Merkur Bets Malta, NOVOLINE.DE, Skill On Net and Tipico Karlsruhe. The fifth is Bavaria’s state casino administration (Staatliche Lotterie- und Spielbankverwaltung), which runs its own online offer. No other Land appeared.

So the realistic German offer for a newcomer is slots, poker and betting through the GGL. Online table games require a Land concession or a state operator, and only two Länder have any entry on the whitelist.

Who can apply and what the application contains

Section 4a sets the conditions for sports betting, poker and slot permits. The applicant must disclose its ownership down to every holder of more than 5% of capital or voting rights and every trust arrangement. It must show reliability and expertise for itself and everyone who represents it, the lawful origin of its funds, enough own funds for lasting operation, and a business case that works after taxes. It needs a seat in the EU or EEA, an authorised representative in Germany if it has no seat there, separate German bookkeeping, a payment account in Germany or at an EU bank, and real-time interfaces for checking every game transaction.

The refusal ground that catches groups is § 4a (1) no. 1 (d). No permit is granted if the applicant, an affiliated company, a controlling person or a company that person controls offers or brokers unlicensed gambling, which the treaty measures against German law.

Under § 4b the application is in writing and in German. It includes a security concept, a social concept, a business plan accounting for taxes, a declaration of no unlicensed gambling and the cost of any expert the GGL appoints to check them. Documents from another EU or EEA state count, as certified copies with certified German translations, at the applicant’s cost. The GGL’s slot application guidance (Merkblatt, June 2026) adds two practical points: an applicant seated abroad files a copy of the gambling licence of its home state, and registry extracts and certificates must not be older than three months.

The GGL publishes no processing time.

What the permit costs

Three costs are fixed by the treaty and one by the regulator’s price list.

The bank guarantee. Section 4c (3) requires an unlimited, directly enforceable guarantee from an EU or EEA bank, covering player payouts and state claims. It is €5,000,000. The GGL may raise it to one month’s expected average turnover, up to €50,000,000. Its slot guidance states that a new guarantee is needed for each new permit period.

The permit fee. Section 9a (4) sets the fee on the approved or forecast stakes in all Länder, in four bands. Where a permit covers several years, each year is calculated separately and later years are reduced by 10%. Our calculation for a five-year first permit, taking constant stakes:

Stakes per year	Band rule	Fee, year 1	Fee, years 2–5 (each)	Five-year total	Year-1 fee as % of stakes
€10m	0.2% (minimum €100)	€20,000	€18,000	€92,000	0.200%
€50m	€80,000 + 0.16% above €40m	€96,000	€86,400	€441,600	0.192%
€100m	€120,000 + 0.1% above €65m	€155,000	€139,500	€713,000	0.155%
€250m	€185,000 + 0.06% above €130m	€257,000	€231,300	€1,182,200	0.103%
€1,000m	€185,000 + 0.06% above €130m	€707,000	€636,300	€3,252,200	0.071%

The bands join without a jump: €40m gives €80,000 under both the first and second band, €65m gives €120,000, €130m gives €185,000. A broker’s permit costs half (§ 9a (4) sentence 5). Supervisory orders cost between €500 and €500,000 each.

LUGAS. Every deposit, limit change or player creation is a query to the central limit file, priced at 0.389 cent per query from 1 January 2023. At a million queries a month that is €3,890.

Tax. The federal Rennwett- und Lotteriegesetz (RennwLottG) taxes sports betting (§§ 16–18), virtual slot games (§§ 36–38) and online poker (§§ 46–48) at 5.3%. The base is the stake “abzüglich” the tax itself, so the tax is 0.053 ÷ 1.053 = 5.033% of gross stakes. The operator files a return for each calendar month and pays by the 15th of the next month (§ 41). An operator seated outside the EU and EEA must name a German tax representative, who is jointly liable (§ 42).

A stake tax behaves very differently from a GGR tax. On slots, gross gaming revenue is the stake minus the payout:

Payout ratio (RTP)	GGR as % of stakes	Tax as % of stakes	Tax as % of GGR
94%	6%	5.033%	83.9%
95%	5%	5.033%	100.7%
96%	4%	5.033%	125.8%
97%	3%	5.033%	167.8%

The RTP levels are illustrations, not market data. The arithmetic is the point: above a 95% payout the tax is larger than the revenue it is charged on. Operators answer that by lowering payout ratios, which the treaty requires them to display at the point of stake (§ 22a (3)).

Online table games under § 22c are not taxed by the RennwLottG; their levy is a matter of Land law, which we have not reviewed for this article.

Product rules that shape the revenue line

The treaty writes the product, not only the licence:

Rule	Provision	Effect
Monthly deposit limit of €1,000 across all operators	§ 6c (1)	Checked in real time against the LUGAS file; no play without a limit set
Limit increases take effect after 7 days, decreases at once	§ 6c (3)	Raising a limit is never instant
Slot stake limit €1 a spin	§ 22a (7)	Raised to €3 / €5 for qualifying players from 1 July 2026 (next section)
Average spin of at least 5 seconds	§ 22a (6)	Caps spins at about 720 an hour
No autoplay, no jackpots, one game at a time	§ 22a (4), (8), (10)	Each spin needs a fresh player action
Separate areas per product on one domain; 1-minute wait to switch, winnings usable in another area after 1 hour	§ 4 (5) no. 5	Cross-selling from betting to slots is slowed by design
Poker: one table at a time, up to four if the GGL allows	§ 22b (5)	Multi-tabling is an exception

What changes between now and 2028

1 July 2026: slot stakes above €1. Section 22a (7) lets the licensing authority adjust the stake limit to changed circumstances. The GGL’s decision guideline, in force from 1 July 2026, allows two stages until 31 December 2027 at the latest:

Stage	Stake per spin	Conditions
Statutory	up to €1	All players
Stage 1	above €1, up to €3	Player aged 21 or older
Stage 2	above €3, up to €5	Stage-1 conditions, plus 90 days without risk flags in the operator’s § 6i monitoring, a dedicated limit-monitoring with quarterly anonymised reports to the regulator, quarterly reporting of flagged players, and the player’s prior consent to the data processing

The GGL’s FAQ says the increase is voluntary, decided by each operator for each player, and that a player can enter stage 2 directly if all conditions are met. Its example: a player clean in monitoring since 1 July 2026 completed the 90 days on 29 September 2026.

31 December 2026: the deposit-limit exception ends. Section 6c (1) sentence 3 lets the permit allow an operator to set a different cross-operator deposit limit for individual players. The GGL’s guideline on that power permits limits above €1,000 and up to €10,000 where the player proves affordability with documents (tax assessments, income evidence, bank statements; self-declarations do not count), re-checked every year, and under special monitoring reported every six months. Limits above €10,000 and up to €30,000 are allowed for at most 1% of an operator’s active players, aged 21 or older, under closer monitoring. Nothing above €30,000 is allowed, and operators may not advertise the higher limits. The guideline applies “bis längstens zum 31. Dezember 2026”, which is 50 days after this article’s publication. We found no successor guideline on the GGL’s site on 11 November 2026.

31 December 2026: the evaluation report. Section 32 requires the Länder, with the GGL and the advisory board, to evaluate the treaty’s effect on the black market and on player protection, with a summary report due by 31 December 2026 and then every five years. In its 22 September 2026 release the GGL asked for that evaluation to be used to make regulation more adaptable. Any change to fees, limits or the product split would come through an amending treaty after it.

31 December 2028: the first exit date. The treaty runs for an indefinite period, but each Land may terminate it with a year’s notice to the end of a calendar year, for the first time to 31 December 2028 (§ 35 (4)).

Enforcement in numbers

The GGL’s own figures, from its 22 September 2026 release: about 100 staff, more than 600 supervisory procedures against licensed operators in 2025, two permits revoked so far, and prohibition proceedings against illegal offers up from 68 in 2022 to 287 in 2025. By the end of 2025 it had checked about 6,300 websites for illegal gambling or its advertising. Enforcement increasingly targets payment providers, affiliates and hosting services, which § 4 (1) supports by banning participation in payments for unlicensed gambling.

How Germany compares

Germany is one of the few EU markets where a single permit covers the whole country but the licence fee floats with turnover and the tax ignores payout ratios. The Netherlands taxes GGR; Italy sells concessions only by tender; Denmark charges a banded fee and a duty on revenue. A Malta licence, held by most GGL licensees, gives no right to serve German players on its own; the MGA, UKGC and Gibraltar comparison explains why EU passporting does not exist for gambling.

The Germany profile keeps the licence requirements, product rules and how to check a licensee in one place. The whitelist counts in this article are a reading of 11 November 2026. The list changes as permits are granted, expire or are revoked.