Germany’s plans for higher online gambling deposit limits remain uncertain after administrative courts questioned whether SCHUFA-G is suitable for assessing players’ financial circumstances. Operators could see the standard monthly limit of €1,000 return if temporary permissions to offer higher limits are not renewed before they expire at the end of the year.
SCHUFA-G allows operators to assess whether a player may qualify to raise the cross-operator monthly limit under the State Treaty on Gambling (GlüStV) from €1,000 to €10,000. But courts have questioned whether the tool measures a player’s assets, wealth and broader financial circumstances, rather than just creditworthiness. They have considered it unlawful and unsuitable, leaving regulators to identify an alternative.
Decision expected at November meeting
The issue was discussed at a recent Gaming in Germany webinar by Gaming in Europe, titled ‘The German iGaming market in 2027 and beyond’. Dr Joerg Hofmann, Senior Partner at Melchers Law, said the Gemeinsame Glücksspielbehörde der Länder (GGL) could not decide the matter alone, with its administrative board also involved. The board has met twice without reaching a conclusion, and is due to meet again on 18 November.
Hofmann warned that a decision is needed at that meeting to avoid the risk that current permissions are not extended or renewed. If they lapse, players would return to the €1,000 standard limit, except where they have set a lower limit themselves.
Possible alternatives under discussion include open banking practices such as Kontoblick, as well as allowing players to upload documents. These could include proof of income or other evidence that an applicant can afford a higher limit. Hofmann said the outcome was not predictable.
He advised operators to apply for new permissions to increase limits as soon as possible, if they have not already done so. That would give the GGL time to process applications after the administrative board reaches and communicates its decision.
Operators warn of black market risk
Hofmann said a reduction from limits of €10,000 or €30,000 to €1,000 could prompt players to move to unlicensed operators in search of higher deposit opportunities. The risk of migration to the black market is familiar to operators, but there is concern over whether decision-makers understand its scale.
The webinar was moderated by Gaming in Europe Content Director Jeroen Laemers. Christian Heins, Founder of European Gambling Gathering (EGG), discussed efforts to address black market advertising, including EGG’s communications with Big Tech companies about evidence of such advertising on their platforms. Dr Nepomuk Nothelfer, Attorney at Melchers Law, discussed the potential regulation of esports betting in Germany. Other topics included a recent Halle Administrative Court ruling, esports betting and the possibility of permitting sweepstakes.
