The two strictest large markets
Germany and the Netherlands are Europe's largest economies after Britain and France, and both licensed online gambling late: Germany in July 2021 after two decades of state monopoly, court defeats and interstate argument, the Netherlands in October 2021 after a decade of parliamentary delay. Both designed their regimes to be strict from the start, both have tightened them since, and both are now the reference cases in the argument about whether strictness channels players or drives them away. An operator in either market runs a different product from the one it runs in Britain, and this lesson explains why.
Germany: the Interstate Treaty
Gambling in Germany is a matter for the sixteen states (Länder), and the framework is an interstate treaty they all sign. The 2008 treaty prohibited online gambling outright; the Court of Justice found it inconsistent (the states restricted private operators while promoting their own lottery); a 2012 revision licensed a handful of sports betting operators through a process the courts struck down; and through the 2010s the German online market was served almost entirely by operators licensed in Malta and Gibraltar under the free-movement claim, with Schleswig-Holstein briefly licensing on its own. The 2021 Interstate Treaty on Gambling (Glücksspielstaatsvertrag 2021, GlüStV) ended that. It took effect on 1 July 2021, licensed online sports betting, online poker and online slots ("virtual slot machines") nationwide, left online table games to individual states to license or not, and created a joint authority of the states, the Gemeinsame Glücksspielbehörde der Länder (GGL) in Halle, which took full responsibility in January 2023.
The treaty's product rules are the strictest in any large market. Online slots were limited to a stake of one euro per spin, a minimum spin of five seconds, no autoplay, no jackpots and no parallel play across products; in July 2026 the GGL exercised a power in the treaty to raise the stake limit to a tiered structure (one euro for under-21s, three euros for adults, five euros for customers with no signs of harmful play over a ninety-day qualification period), the first such adjustment and a concession to channelisation arguments. A cross-operator deposit limit of 1,000 euros a month applies by default, enforced through the LUGAS central system that every licensee reports to and that also prevents simultaneous play with more than one operator; higher limits are possible with affordability evidence. Online table games (roulette, blackjack) are licensed only by the states that have chosen to, on a limited basis. The national self-exclusion system, OASIS, must be checked at every login. Tax is charged on stakes rather than revenue: 5.3 per cent of stakes on online slots and poker and 5.3 per cent on sports bets, a structure that makes high-turnover, low-margin products punitive and is the industry's main complaint.
Advertising is permitted but constrained: no television or online advertising for slots and poker between six in the morning and nine at night, no advertising to minors or with active athletes, no promotion of unlicensed products, and affiliate and influencer marketing under the licensee's responsibility. Enforcement against unlicensed operators runs through payment blocking, domain blocking and administrative proceedings, and the GGL publishes its actions and a whitelist of licensees.
The treaty requires an evaluation, due in 2026, of whether it has achieved its aims, and the evaluation is the political event of the German market: the industry argues that stake limits, the stakes tax and product restrictions have left channelisation for online slots at around half, the GGL and the states argue that channelisation is higher and rising, and the GGL's 2026 stake-limit decision and its expansion of LUGAS are read as the authority preparing its case. Whatever the evaluation concludes, the German model of a central deposit limit, a central self-exclusion check and product-level restrictions has been copied elsewhere.
The Netherlands: KOA and its reversal
The Netherlands ran online gambling as a prohibition with tolerance for a decade, then passed the Remote Gambling Act (Kansspelen op afstand, KOA) in 2019, brought it into force in April 2021 and opened the market on 1 October 2021 under the Kansspelautoriteit (KSA). The regime licensed casino, poker, betting and bingo with a 29 per cent gaming tax on gross gaming revenue, a "cooling-off" rule that kept operators that had served Dutch customers unlicensed out of the first licensing rounds, the Cruks national self-exclusion register, mandatory identity verification and a duty of care that required operators to monitor and intervene. The launch was a commercial success and a political failure: advertising volume in the first year, with famous role models fronting campaigns, produced a public reaction that has driven every change since.
The changes came fast. Role models were banned from gambling advertising in June 2022; untargeted advertising (television, radio, outdoor, print) was banned from July 2023, leaving only targeted online advertising to opted-in adults over 24; sponsorship of events and sports was phased out by July 2025; bonuses were prohibited for under-24s and restricted for everyone. From October 2024, mandatory deposit limits took effect: a default net deposit limit of 700 euros a month (300 euros for customers under 25), above which a customer may set a higher limit only after the operator has contacted them and, for larger amounts, verified that the spend is affordable. Gaming tax rose from 30.5 per cent to 34.2 per cent in January 2025 and to 37.8 per cent in January 2026, a two-step increase enacted to fund the government's budget.
The results have been the subject of an argument the industry lost and then partly won. The KSA's own monitoring showed channelisation falling after the deposit limits and the advertising ban, with high-spending customers moving to unlicensed sites in the largest numbers; the tax increase raised far less than forecast (a joint assessment by the finance ministry and the KSA in 2026 found the additional revenue a fraction of the projection, as licensed revenue fell); and the government that came into office after the late-2025 election inherited an evaluation of the KOA framework with proposals to raise the minimum age for online casino to 21, to tighten advertising further and to strengthen the duty of care. The Dutch case has become the example each side cites: for regulators, proof that strong measures reduce harm; for the industry, proof that strong measures at a high tax rate move the market offshore.
What the two markets share
Both regimes centralise player protection in national systems (LUGAS and OASIS in Germany; Cruks and the deposit-limit rules in the Netherlands) rather than leaving it to operators. Both restrict advertising by time, channel and audience, and both have moved against role models and sponsorship. Both restrict products (Germany's slot rules, the Netherlands' bonus and limit rules) in ways that change what a customer can play. Both tax at rates that the industry describes as unsustainable: Germany through a stakes tax that penalises low-margin products, the Netherlands through a revenue tax approaching 40 per cent. And both are now being evaluated, with channelisation as the measure and the unlicensed market as the counter-argument.
What the two markets teach
The German and Dutch experiences have shaped regulatory design across Europe. Central deposit limits and cross-operator systems have been adopted or proposed in other markets; the Dutch advertising sequence (role models, untargeted, sponsorship) has been followed in Belgium and discussed elsewhere; and the channelisation debate both markets produced is now the language of every consultation. For operators the practical lesson is that product, marketing and pricing have to be designed per market, and that a business model built on high-value customers and bonus-led acquisition does not transfer to either. For regulators the lesson, still being argued, is where restriction stops channelling and starts leaking.
What to take from this lesson
Germany licenses online slots, poker and sports betting nationally under the 2021 Interstate Treaty through the GGL, with stake limits (tiered from July 2026), a five-second spin, a 1,000 euro cross-operator deposit limit through LUGAS, OASIS self-exclusion, a 5.3 per cent tax on stakes, time-restricted advertising and a 2026 evaluation pending. The Netherlands licensed under KOA in 2021 through the KSA and then reversed course: role models, untargeted advertising and sponsorship banned by 2025, mandatory deposit limits from October 2024, gaming tax at 37.8 per cent from 2026, and a KOA reform under a new government after channelisation fell and tax revenue missed forecasts. Both markets centralise protection, restrict products and advertising, and are the reference cases in Europe's channelisation debate.