The 2021 State Treaty on Gambling: which limits apply and what casinos without a German licence mean
The rules for players with provision and primary source.
The 2021 State Treaty on Gambling (GlüStV 2021) sets firm limits for online gambling in Germany: a cross-operator deposit limit that as a rule may not exceed €1,000 per month, a maximum stake of €1 per game for virtual slot games and an average game duration of at least five seconds. These rules bind operators holding a German permit, meaning the operators on the GGL whitelist.
Anyone searching for online casinos ohne Limit usually ends up with operators that are not on this list. According to the GGL, such operators lack player protection measures such as deposit limits or self-exclusion.
Permits and the GGL whitelist
The starting point is § 4 (1) GlüStV: public games of chance may only be organised or brokered with a permit from the competent authority of the respective federal state. Unauthorised gambling is prohibited, and so is taking part in payments for it. Under § 4 (4), only lotteries, sports and horse-race betting, online casino games, virtual slot games and online poker can be licensed online. For everything else the treaty says: “Im Übrigen sind das Veranstalten und das Vermitteln öffentlicher Glücksspiele im Internet verboten.” (in all other respects, organising and brokering public gambling online is prohibited)
Online casino games in the narrow sense, meaning banked games such as roulette and blackjack, are regulated by the states themselves; as of May 2025 there were 5 concessions for them, in Schleswig-Holstein and Bavaria. Slot operators with a GGL permit may not use the term “Online Casino”, and under § 22a (11) the words “Casino” and “Casinospiele” are not permitted for virtual slot games. Which table limits for roulette and blackjack the five brands state is shown on the page about live casino without limits with all known figures.
Online supervision lies mainly with the Joint Gambling Authority of the Federal States (GGL). Under § 27a the states set it up on 1 July 2021 as a public-law institution based in Saxony-Anhalt. Under § 9 (8) the authority publishes a “gemeinsame amtliche Liste (Whitelist)” (joint official list) of all licensed operators and brokers. It is updated at least monthly, the GGL page last on 02.10.2026, and it can be filtered by virtual slot games, online poker, sports betting and online casino games, among others.
The GGL states the consequence without qualification: “Alle Glücksspielangebote im Internet, die nicht auf der Whitelist stehen, sind illegal.” (all online gambling offers not on the whitelist are illegal) An offer stays illegal until the application is approved and the operator is listed; the authorities give no information about pending applications. Under § 6e (3), licensed operators use a .de domain exclusively, show the ban on players under 18 together with permit and supervisory authority on the start page; according to the GGL, they also receive a seal of approval. According to the GGL, a registered office in Germany is not required, while an offer without .de is always unauthorised.
The GlüStV limits at a glance
The central limits are found in §§ 6c, 6h and 22a GlüStV. The best known is the €1,000 deposit limit: under § 6c (1) every player sets an individual monthly, cross-operator limit when opening an account. Without a limit set, there is no participation in play. Monitoring runs through LUGAS, the cross-state supervision system made up of the limit file and the activity file; the limit resets on the first day of each month, and failed payments count as well.
An increase only takes effect after a protection period of seven days, while a reduction applies at once. According to the GGL, a limit of up to €10,000 per month requires inconspicuous gaming behaviour and proven financial capacity; a self-declaration is not enough. Above €10,000 up to €30,000, only at most 1 % of active players per operator qualify. In addition, under § 6c (2) operators must offer daily, weekly or monthly stake, deposit and loss limits; once these are used up, no further play is allowed.
For virtual slot games the game rules of § 22a apply on top. Paragraph 6: “Ein Spiel muss durchschnittlich mindestens fünf Sekunden dauern.” (a game must last at least five seconds on average) It is measured from the player’s declaration to the display of the result. Paragraph 7: “Der Einsatz darf einen Euro je Spiel nicht übersteigen.” (the stake may not exceed one euro per game) The competent authority may adjust the maximum stake to changed circumstances. According to the GGL, from 1 July 2026 a tiered, temporary deviation is possible under GGL conditions: up to €3 from the age of 21, up to €5 after 90 days of gaming behaviour without signs of addiction, limited until 31.12.2027.
§ 6h prohibits parallel play with several operators. The player is switched to active via the activity file, and a waiting period of five minutes applies when switching. After every 60 minutes a notice on the elapsed playing time must be confirmed; for virtual slot games play may only continue five minutes later.
The payment route is restricted too. Under § 6b (4), deposits and withdrawals only run through a payment account in the player’s name, and anonymous means of payment are not permitted in distance selling. The Money Laundering Act allows an exception in § 16 (4) if no more than €25 per transaction and €100 per calendar month are deposited. What this means for prepaid credit, and which alternatives exist, is described on the page about paying with Paysafecard. Before the player’s details are confirmed, § 6a (4) exceptionally allows play for 72 hours after account opening up to a deposit limit of €100; withdrawals only follow confirmation.
Licences of the 5 casinos
The five brands on this site state licences from other jurisdictions, and for Rabona and Spinsy casino.guru reports no valid licence at all; there is no information on a German licence for any of them. Tsars Casino states a licence from Anjouan (Comoros), licence no. ALSI-202503021-FI1, operated by TRINK N.V. Goldenbet Casino runs under a licence of the Curaçao Gaming Authority, OGL/2024/1798/1048, operated by Santeda International B.V.
For Slotum Casino the sources differ: according to casino.guru Anjouan (Comoros) ALSI-202508056-FI2 and Tobique Gaming Commission (New Brunswick) 0000002, according to the operator terms 09/2025 Curaçao Gaming Control Board OGL/2023/174/0082. casino.guru and AskGamblers 2026 name Novatrix S.R.L. as operator, the 09/2025 terms Dama N.V., Curaçao. For Rabona Casino casino.guru reports no valid licence, while AskGamblers names PAGCOR and the Anjouan Gaming Board; the operator is Naale Limited according to casino.guru and Stellar Ltd according to AskGamblers. Spinsy Casino has no official licence according to casino.guru and one from the Tobique Gaming Commission according to AskGamblers; operator NovaForge Ltd according to casino.guru, Dreamline Ventures SRL according to AskGamblers.
According to the sources, all five accept players from Germany, Tsars, Slotum, Rabona and Spinsy explicitly according to casino.guru. For Spinsy, Germany is not on the list of Excluded Jurisdictions in operator terms 2.3. A full-text search of the GGL whitelist for the operator names Santeda and Dama N.V. returned 0 hits.
The brands still state their own limits. Slotum gives EUR max. 4,000 per payment method on its payments page and caps the stake on card games at €1,000. Goldenbet lists live tables from €0.10 with stakes up to €20,000 according to LCB. With an active bonus, maximum stakes apply: €5 at Goldenbet, Slotum and Rabona; at Tsars, according to casino.guru, €2 with an active 1st and 2nd deposit bonus and €5 with the 40 % and 25 % bonus; at Spinsy €100 according to the operator and €5 according to casino.guru. In the German system, by contrast, only the licensed operator decides on a higher deposit limit, and the GGL cannot change the limit. How raising the LUGAS limit works and which waiting period applies is explained on the dedicated page.
According to the sources, bonus buy slots are offered by Goldenbet, by Slotum with a filterable “Bonus Buy” category, by Rabona with a “Bonuskäufe” category and by Tsars with a “Feature buys” category according to a player; for Spinsy there is no information. At Tsars, autoplay was used in slots according to a player report; for the other brands there is no information. Under the GGL minimum requirements of 2024, autoplay including series automation is prohibited on licensed slots, and § 22a (8) bans jackpots. What applies in detail to autoplay, jackpots and bonus buy on German slots is covered in a separate overview.
Taking part in unauthorised gambling: § 285 StGB
The State Treaty addresses operators; for players the Criminal Code is what counts. § 285 StGB opens with the sentence “Wer sich an einem öffentlichen Glücksspiel (§ 284) beteiligt, wird mit Freiheitsstrafe” – participation is punishable by imprisonment of up to six months or a fine of up to 180 daily rates. This refers to taking part in unauthorised public gambling, that is, an offer without a permit.
The GGL lists criminal liability as one of the risks with unlicensed operators. Further risks according to the GGL: missing player protection, refused payouts of winnings, data misuse and the inability to enforce claims. In its own words: “Illegale Veranstalter verweigern oft die Auszahlung von Gewinnen” (illegal operators often refuse to pay out winnings). The GGL is not responsible for transaction problems; civil claims such as the payout of balances, data protection and player exclusions are also outside its remit. It does, however, accept reports of unauthorised gambling, irregularities at licensed operators and suspected money laundering.
Player exclusions run through a nationwide exclusion file. According to the GGL, it is checked at account opening and at every sign-in. Operators query it with surname, first name and date of birth; the answer is only “Der Spieler ist nicht gesperrt” or “Der Spieler ist gesperrt” (the player is not excluded / is excluded). Excluded players may not take part in public gambling, and operators may not urge them to have the exclusion lifted; after an exclusion ends, bonuses or discounts for this are not permitted. A request for self-exclusion or third-party exclusion can be filed not only with the operator but also directly with the body that keeps the exclusion file.
This exclusion file is called OASIS and is run by the Regional Council of Darmstadt. According to the GGL, legal operators must use it, and operators without an OASIS connection are illegal. What the limit file and activity file record and what casinos without LUGAS mean for deposits and player protection is explained on a separate page. Connected operators offer self-exclusion from three months, third-party exclusion of at least one year and the 24-hour block via a panic button; the exclusion request and the request to end it are free of charge for players.
Payment blocking and network blocking
Besides criminal law, the authority has two tools against unauthorised offers. Under § 9 (1) no. 4 GlüStV it may, after notification, prohibit banks and payment service providers from taking part in payments for unauthorised gambling and in payouts from it.
Under § 9 (1) no. 5 the authority may also, after notification, take “Maßnahmen zur Sperrung dieser Angebote” (measures to block these offers) against service providers such as access providers and registrars. This is the basis for network blocking. For Slotum, casino.guru warns that access from Germany is blocked by a network block and that VPN use is not allowed.
In the licensed market, § 16 (7) of the Money Laundering Act also applies to withdrawals: they may only be made by payment transaction to a payment account in the player’s name, stating the purpose. If the player changes payment or bank details, withdrawals are only permitted to the previously stored account until the new details are verified.
The five-second requirement of § 22a (6) is a condition for licensed virtual slot games; for the five brands, there is no information on the five-second rule at all. What defines casinos without the 5-second rule and where the rule does not apply is explained on the related page.
Under § 6b (2), deposits and winnings must be credited without delay, and withdrawals must be deducted from the account without delay once requested. Player balances are held separately from operator funds in trust accounts and must be protected against insolvency. If the account is closed, the balance must be transferred within five working days at the latest; fees for closure and payout are not permitted. Under § 6d, players must be able to view their balance, game history, deposits and withdrawals and limits for the last twelve months at any time. The due diligence obligations of the Money Laundering Act apply to gambling operators as a rule for winnings or stakes from €2,000; under § 16 (1) GwG this threshold does not apply to online gambling.
Virtual slot machine tax 5.3 %
Virtual slot games have their own tax under the Racing Betting and Lottery Act (RennwLottG). Under § 36 RennwLottG, online replicas of slot machine games are taxable if the organiser is based in Germany or the player concludes the gaming contract in Germany. The rate is set in § 38: “Die Virtuelle Automatensteuer beträgt 5.3 Prozent der Bemessungsgrundlage nach § 37.” (the virtual slot machine tax is 5.3 percent of the tax base under § 37) The tax base is the stake placed minus the tax itself.
Under § 39 the tax debtor is the organiser, not the player. A different standard applies to players: according to the Federal Fiscal Court (X R 8/21), poker remains a private activity without tax consequences for leisure and hobby players; anyone who systematically aims at income can generate commercial income subject to income tax.
The tax is tied to the same game type for which § 22a sets the game rules. Under § 22a (5), virtual slot games run only in euros and cents, and conversion into other currencies is prohibited; the payout rate and the probability of the top win must be clearly displayed. Under § 6e, random number generators must be checked by independent experts before use and at least once a year, with the results sent to the authority. What the 5-second rule on slots means for every single spin is shown in detail on the dedicated page.
For the same game type, § 22a prohibits playing several virtual slot games at the same time, including the same game, as well as program sequences that automatically start another game once one has ended; a game only starts on the player’s declaration. Under § 6j, licensed operators may only offer free demo versions to players with an account, and the demo must match real-money play except for payment and cash winnings. If an operator offers different forms of gambling on one domain, under § 4 (5) they run in separate areas: switching is possible after one minute at the earliest, and winnings from one area can only be used in other areas after one hour.
Reclaiming losses: the 2026 Federal Court of Justice case
Whether players can reclaim losses from operators without a German permit is decided by the civil courts. The Federal Court of Justice (BGH) has opened a “Leitentscheidungsverfahren zur Erstattung von Verlusten bei unerlaubtem Online-Glücksspiel”, a leading-decision procedure announced in press release no. 086/2026 of 20.05.2026. The case number is I ZR 216/25.
In the case, a player is reclaiming €10,092 in losses from online casino games in the years 2020 to 2022 from an operator without a German permit. The lower courts ruled in the player’s favour. The hearing was scheduled for 17.09.2026; there is no information on the outcome.
FAQ
Which deposit limit does the State Treaty on Gambling prescribe?
Under § 6c (1) GlüStV every player sets a monthly, cross-operator deposit limit that as a rule may not exceed €1,000 per month. According to the GGL, more is only possible up to €10,000 with proven financial capacity and up to €30,000 for at most 1 % of active players per operator.
Are there other limits besides the statutory deposit limit?
Yes. Under § 6c (2) operators must additionally offer daily, weekly or monthly stake, deposit and loss limits. For slots, a maximum stake of €1 per game also applies under § 22a (7); what defines casinos without the 1-euro limit and what applies to the stake per spin from July 2026 is covered on a separate page.
Where is the 5-second rule in the State Treaty on Gambling?
In § 22a (6) GlüStV 2021. The legal text is published, among other places, in the Bavarian legal collection (BayRS).
What does the 5-second rule say?
“Ein Spiel muss durchschnittlich mindestens fünf Sekunden dauern” – a game must last at least five seconds on average, measured from the player’s declaration to the display of the result. The rule applies to virtual slot games of licensed operators.
Is a casino without a stake limit legal?
According to the GGL, all online gambling offers that are not on the whitelist are illegal. Licensed slots have a maximum stake of €1 per game; from 1 July 2026, under GGL conditions and limited until 31.12.2027, a deviation up to €3 from the age of 21 and up to €5 after 90 days of gaming behaviour without signs of addiction is possible.
Is playing at casinos without a German permit a criminal offence?
§ 285 StGB provides for imprisonment of up to six months or a fine of up to 180 daily rates for taking part in unauthorised public gambling. The GGL lists criminal liability as a risk with unlicensed operators.
More topics
The other comparisons and all profiles at a glance.
Glücksspiel kann süchtig machen. Spielen Sie verantwortungsbewusst und nur mit Geld, dessen Verlust Sie verkraften. Hilfe und Beratung bieten die BZgA unter check-dein-spiel.de und die Suchtberatungsstellen der Länder, kostenlos und anonym.