Many users of online sports betting associate a German license with clear expectations: a regulated market, effective player protection and reliable payouts.
This trust is shaken when a licensed provider not only reaches its limits, but significantly exceeds them and ultimately even withholds profits.
The legal framework is clear. Section 6c of the State Treaty on Gambling 2021 obliges providers of online sports betting to a provider-wide monthly deposit limit, which may not exceed 1,000 euros. Once the personal limit is reached, no further deposits may be made. The provider is obliged to ensure this “through appropriate measures”.
The Joint Gambling Authority of the Länder describes the underlying system as follows: Compliance with the limit is monitored via the central limit file (LUGAS). Once the limit is reached, further deposits must be technically prevented.
At the same time, there is the possibility of an exception: An increased deposit limit can be up to 10,000 euros per month. According to GGL, a further tier of over 10,000 to 30,000 euros is only permitted for a maximum of one percent of a provider’s active players.
This means that a monthly limit of 30,000 euros is the absolute upper limit in the licensing system – beyond that, player protection is no longer guaranteed.
This is precisely where a recent case from our practice comes in, raising significant questions.
A player represented by the law firm Cocron was able to make deposits of over 40,000 euros with a licensed provider within less than a month.
Damit wurde nicht nur das Standardlimit überschritten, sondern auch die maximale High-Limit-Stufe von 30.000 Euro deutlich überschritten.
Aus den abgegebenen Wetten ergab sich ein Gewinn von mehr als 20.000 Euro.
The provider not only ignored the legal deposit limits, but also subsequently refused to pay out the winnings.
The combination of effectively circumventing the limit system and subsequently (partially) refusing payment is particularly critical. In such cases, it is no longer just about technical errors, but about the integrity of the market.
Licensed providers must not behave like a “black market light”.
The regulatory relevance becomes even clearer when looking at the licensing requirements. The 2021 State Treaty on Gambling requires, among other things, a security deposit in the form of an unlimited, unconditional bank guarantee of at least 5 million euros to secure payment claims.
This is not merely a detail, but a clear signal from the legislator: profits should not be lost simply because a provider refuses to pay.
The state treaty also provides for graduated supervisory measures – up to and including the withdrawal of the license.
The central question is therefore: How many serious violations will the GGL tolerate before it actively intervenes and consistently uses its supervisory powers?
It is undisputed that the GGL holds nationwide oversight of online gambling. We have informed the authorities about the case and requested an investigation. At the same time, it is known that GGL does not process individual complaints regarding payouts. Therefore, in practice, two procedures usually run in parallel: civil enforcement and regulatory review of systemic problems.
What does this mean for those affected?
The deposit limit is not a recommendation, but a binding technical obligation according to § 6c GlüStV 2021.
The high-limit level up to 30,000 euros is a narrowly defined exception and not the rule.
A license does not protect providers from consequences – up to and including revocation.
In addition, a legally required bank guarantee secures the players’ claims.
Procedure in comparable cases
Secure all relevant documents such as bank statements, deposit histories, betting slips and communications.
Request a full statement and payment from the provider in writing.
Report any suspicious activity via the GGL reporting portal.
Check your civil law claims at the same time.
We will report on further developments.
