What does GluNeuRStv mean to German casino players?

The first phase of the new countrywide legislation for online gambling in Germany is set to come into being on October 15^th, with the full implementation of the new laws expected to be in place by the 1^st July 2021.

On the face of it, the new legislation, which was required to clarify and provide uniformity to the laws in Germany with regards to online sports betting, casino gaming and other forms of online gambling, is a good thing, with fears that an outright ban on some gambling options proving to be incorrect. However, that is not to say that the new restrictions do not come without a long list of new rules, regulations and caveats, many of which have been put into place in the name of player protection.

So, what will these new regulations mean for players in Germany? In order to fully understand what a German slots or casino game player may now experience when playing in the country, we first need to get a grasp of the new legislation in a bit more detail.

What are the key aspects of the new gaming legislation in Germany?

The quest for greater clarity and transparency, plus the opportunity to greater protect German players when betting in any form online, has been the driving force behind the new legislation and the new 'online gambling toleration regime' as it is being called does have many aspects to it, covering all aspects of online gaming, even down to how casinos are allowed to market themselves to players within Germany.

The regulatory framework is called the "Glücksspielneuregulierungsstaatsvertrag" which doesn't easily roll off the tongue for non-native German speakers, so has been shortened to GlüNeuRStv in many cases and it is a far-reaching set of regulations that encompasses all different forms of online gambling and in particular how German customers can access them, and what casinos can (and cannot) offer to German players.

The phased roll out of the new regulatory framework will begin from October 15^th but is expected to be fully incorporated across Germany by the 1^st July 2021.

So, let's first deal with some of the positive aspects of the new regulatory framework for players in terms of what can be offered in Germany with the new framework.

Sports betting, online casino gaming and poker are all permitted in Germany under the new guidance, provided the casino adheres to the regulations within the framework for each.
15 companies have already been awarded sports betting licenses to operate in Germany. The 15 companies in receipt of the new licenses accounted for 75% of the total spent on sports betting in Germany last year.

However, the guidance also contains a number of references regarding what a casino can and cannot offer players and it is these laws and rules that have been met with some consternation by many in Germany who feel that their gambling liberties are set to be infringed. Some of the key regulations that will have a direct impact on German players are:

Sites will only be allowed to offer a player bonuses worth up to €100 per year in value.
Initially, people will only be allowed to wager a maximum of €1,000 per month. There is scope within the framework for this to be raised to €10,000 per month provided that certain conditions are met.
New players will also find deposit restrictions on their account until they have completed a customer verification process when it is expected some of these restrictions will be lifted.
Players that enjoy In Play betting on sports such as football will find that they only have limited markets available to them with the Next Goalscorer and Final Result markets being the only one that companies are allowed to offer.
Slot games will have a maximum stake limit of €1 per spin set.
Each slot game must see the reels spin for at least five seconds before they resolve.
Casinos must ensure that players cannot open another window in their browser or on their device to play a second or third slot game or similar at the same time as they are playing another game. Operators have until the 15^th December 2020 to implement the changes above for slot games.
Until the full guidance is implemented in July 2021, table games such as blackjack and roulette are not allowed to be offered to players.
Casinos, poker and sports betting operators that hold a German license are banned from using affiliate advertising to attract new customers. They are also forbidden to pay affiliates any money for any leads and conversions that the affiliate provides to the site. This has led to a number of providers contacting affiliate sites asking them to modify and edit their German-facing sites, or even stop their marketing to German customers, at least for the time being.
Affiliates or marketing for the new casinos will also be forbidden from promoting table games such as roulette, blackjack and baccarat, Live Casino games will also not be allowed to be promoted and promotion of jackpot games, including progressive jackpots, will also be banned,
Incredibly, the use of the words "casino", "casinos" or "casino games" has been banned when promoting new German casino sites, and this extends not just to the written word, but also to the inclusion of the word in advertising logos or banners.

While there are a lot of these new measures that do make sense in terms of player protection, such as the limits on how much you can wager a month, deposit limits and even upper limits for how much you can bet on slot games, some of the other measures, notably the banning of using affiliate sites for marketing and that casinos are not allowed to use a number of words relating to their service in their advertising, does seem excessive.

Of course, the actual framework contains a great deal more information than what is listed above and so comprehensive is it that rather than rolling out the Framework immediately, Germany is starting the process of making all its licensed sites compliant from October 15^th this year, with the idea being that by July 1^st 2021, all sites in the country will be fully compliant with the GluneuRStV.

What does this mean for the average German customer?

As you can see from the data above, there are a number of positives for German punters. Firstly, they will still be able to access sites that offer sports betting, casino gaming and poker over the long term (even if, in the short term, not all of the attractions on the sites will be available). This is a positive as there had been concerns that Germany could ban certain betting options for customers.

Secondly, the much clearer regulation of the industry means that there are far less 'grey' areas within the industry which could offer less than reputable companies to operate and exploit German customers. Furthermore, the player protection rules mean that Germany will have some of the strongest gambling protection laws in the world.

However, for those positives, there are going to be much more negatives for players.

Capped bonuses of €100

One of the most immediate effects of the new legislation will be a sea change in the types of bonuses German players can receive. With the new regulations only allowing a casino to offer bonuses of up to €100 a year in value to players, this could well mean much smaller, or significantly fewer promotions and bonuses available at the new generation of German casinos. In the long term, that will only offer players poorer value for money.

This legislation does seem to have been copied from Sweden, where similar legislation on bonuses is already in place for Swedish-based players.

Maximum monthly spend/deposit limits

Perhaps the most obvious way to control players spending was to introduce monthly spend and deposit limits at sites and unsurprisingly that is a key aspect of the new regulations. In truth, the deposit limits at present (€1,000 per month for standard players, with a few provided they can meet the requirements, can increase this to €10,000 per month) are generally enough for all but the higher roller players and so they should not have too great an impact on the majority of German players, who would usually deposit less than this amount anyway.

However, it does mean that for higher roller players, playing games in Germany is not as attractive as they are limited in how much they can spend at their choice of casino and as such, they could well choose to take their custom elsewhere. It will be interesting to see if this has a knock-on effect on casino yearly revenues if this proves to be the case.

Maximum bet size of €1 on slot games

While having a ceiling on slot games is a good idea to control gambling on these particular types of games, setting a limit of €1 is a measure which is going to have a significant impact, especially on players that preferred to wager more per spin, in the hope of landing some of the potentially larger wins available on slot machines.

For players who play small stakes or micro stakes, this upper limit won't be of any concern as they would likely have played slots for less anyway, but for medium to higher stakes players, it could severely impact the enjoyment and excitement that they get from a game.

There's also a practicality issue here. If a player is allowed to deposit €1,000 a month, or even if they qualify for the upper €10,000 a month limit, if they wanted to play that money on slots that would require them to play through 10,000 spins of their game, that is a significant amount of time and that may not be a practicality for many higher rollers, who may not have that kind of time to invest playing so many spins.

Most common search terms being banned from marketing

This for me is the strangest aspect of all the regulations imposed by the GluneuRStV and it is the one that I feel has the potential to be counterproductive. Given that the new regulations forbid casinos from using words like casino, casinos or casino games in their marketing or even the titles of their online site (which will facilitate either a massive revamp of existing sites in Germany, many with name changes, or a complete build of a brand new site that is GluneuRStV compliant), the question is how will players find these casinos using a search engine?

Of course, casinos will try to come up with a memorable name for their site and will try and use as many synonyms for casinos as they can think up, but there is no doubt that if you are looking for an online casino, the first word you would type into a search engine is likely to be casino or something similar.

This is where the problem lies for me as there will be unscrupulous companies that are well aware of the fact that German player searching for casinos may well use these terms and if these sites can rank highly enough, they could tempt German players to play there, by offering them a way around some of the more draconian laws. Of course, once a player does this, and it is relatively easy to use VPN software to fool software into thinking you are based in another part of the world, then they are no longer protected by the new regulations.

From a casinos perspective, the lack of affiliates and the lack of common terms to define their casino means that entirely new marketing strategies are going to be required to push their products to German customers and it is going to be very interesting to see how that turns out.

German players will now see a phased move towards the full regulations coming into being by July 2021 and it promises to be an exciting, if unusual, few months for German slots and casino players.

Viel glück, euch allen!

Next Post: India Netbanking for Live Casino and Sports Betting