Unauthorized gambling remains criminalized under GGL's current stance
Germany's Proposed Gambling Reform Sparks Debate
Germany is currently considering a significant reform to its gambling laws, with state interior ministers advocating for changes to be reviewed in 2026 [2][3]. This proposed reform, which aims to decriminalize unregulated gambling, has sparked debate among various stakeholders.
One of the key concerns raised by critics is the potential impact on the prosecution of overseas operators. Under the current German gambling regulations, enacted in 2021, strict local licensing and operational rules limit unregulated gambling and target offshore operators [2][3]. However, the reform may soften some prosecution efforts by providing a more inclusive regulatory approach to previously unregulated operators, although the precise mechanisms are still undefined.
The German Gambling Commission (GGL) has been vocal in its opposition to the proposed reform. The GGL advocates for the expansion of the criminal law to encompass illegal gambling providers operating abroad [4]. The GGL CEO, Ronald Bente, has urged the federal ministry of justice to reconsider the planned reform, warning against the potential repercussions, particularly regarding the fight against money laundering [4].
Burkhard Blienert, Germany's drug and addiction commissioner, also opposes the planned law relaxation [5]. Benter argues that the elimination of section 284, which prohibits unauthorized gambling, might result in a "regulatory gap," effectively decriminalizing a substantial portion of money laundering activities [1].
The GGL's stance emphasizes the need for continued legislative measures against illegal gambling. The organization contends that the proposed reform could substantially compromise efforts to combat black market operators in Germany. The GGL also emphasizes the necessity of clarity in applying German law to overseas gambling providers.
Germany's regulatory landscape remains restrictive, with stringent deposit and operational limits. The country legalized online gambling in 2021 but restricts player deposits, betting stakes, and enforces operational limits [1]. Cryptocurrency payments are largely prohibited under AML principles, except those dealt through Curaçao-licensed operators [1]. The reform could potentially introduce more liberal regulations, but it is primarily oriented toward harmonizing state laws before the 2026 treaty review [2][3].
Despite the ongoing debate, AML efforts continue to prohibit anonymous payments and apply strong compliance rules, with cryptocurrency gambling under conditional acceptance mainly via licensed entities [1][4]. As the reform progresses, it remains to be seen how Germany will balance the need for a more regulated online gambling environment with the need for effective control over the industry.
- The proposed gambling reform in Germany has raised concerns among critics about its potential impact on the prosecution of overseas operators, given that it may soften some prosecution efforts by providing a more inclusive regulatory approach to previously unregulated operators.
- The German Gambling Commission (GGL) has vehemently opposed the proposed reform, arguing that it could substantially compromise efforts to combat black market operators in Germany and result in a regulatory gap, effectively decriminalizing a significant portion of money laundering activities.
