The two strictest large markets
Germany and the Netherlands are two of Europe's largest economies (Eurostat's national accounts rank them first and fifth in the European Union by 2025 GDP), and both licensed online gambling late: Germany in July 2021 after years of state monopoly, court defeats and interstate argument, the Netherlands in October 2021 after years of delay, its Remote Gambling Act having been passed in 2019. 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; in 2010 the Court of Justice ruled that German courts could find the state monopoly unfit for its stated aim of fighting addiction where the authorities at the same time expanded higher-risk gambling, such as slot machines, to maximise revenue; a 2012 revision offered twenty sports betting concessions under an experimental clause, a procedure that stalled in litigation and led the Court of Justice to rule in 2016 that Germany could not penalise the unauthorised intermediation of sports bets for bookmakers licensed elsewhere in the EU where that procedure lacked transparency and the monopoly persisted in practice; and through the 2010s operators licensed elsewhere in the EU served German players under the free-movement claim, while Schleswig-Holstein licensed online casino games and poker under its own 2011 law, licences it later extended to 30 June 2021. 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 run or license, and created a joint authority of the states, the Gemeinsame Glücksspielbehörde der Länder (GGL) in Halle, which took over all its tasks 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 game, an average game length of at least five seconds, no autoplay, no jackpots and no simultaneous games; from July 2026 the GGL used a power in the treaty to adjust that limit, letting licensed operators offer stakes of up to three euros to players aged 21 or over, and up to five euros to those who have shown no signs of problem gambling over a ninety-day qualification period and are then specially monitored. One euro remains the default, operators decide whether to offer the higher tiers, and the rule runs only until 31 December 2027; the GGL presented it as a way to keep players in the licensed market, 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 where the player shows the operator that they can afford them. Online table games (roulette, blackjack) are run or licensed only by the states that have chosen to, with the number of concessions capped. The national self-exclusion system, OASIS, run by the state of Hesse for all sixteen, must be checked before a player starts to play. Tax is charged on stakes rather than revenue: 5.3 per cent on online slots, online poker and sports bets alike, a structure that makes high-turnover, low-margin products punitive and is the industry's main complaint.
Advertising is permitted but constrained: no broadcast or internet advertising for online slots, poker and casino games between six in the morning and nine at night, no sports betting advertising featuring active athletes, no advertising aimed at minors, no promotion of unlicensed products, and licensees may commission third parties, such as affiliates, to carry out their advertising (see influencer marketing). Affiliates promoting games that self-excluded players may not play cannot be paid a revenue share or any other commission tied to turnover, deposits or stakes. Enforcement against unlicensed operators runs through payment blocking, prohibition orders, site blocking and administrative proceedings, and the GGL publishes a whitelist of licensees. Blocking suffered a setback when the Federal Administrative Court held in March 2025 that the treaty allowed the GGL to order an internet access provider to block unlicensed sites only where the provider was itself responsible for the content under telemedia law, which an ordinary access provider is not; an amendment applying from July 2026 extends blocking orders to intermediary services, including pure access providers, where action against the operator is not feasible.
The treaty requires a summary evaluation report by 31 December 2026 on its effects on the black market and on player protection, and the evaluation is the political event of the German market: the industry argues that stake limits, the stakes tax and product restrictions push players to unlicensed sites, while a GGL-commissioned survey of 2,000 players found that unlicensed operators took about 23 per cent of reported losses, which the GGL presents as about 77 per cent of the online market on regulated offers. The GGL's 2026 stake-limit decision, and its call for more room to adapt the rules itself, 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 become a reference point elsewhere: the Dutch government now plans an overarching deposit limit held in a central register.
The Netherlands: KOA and its reversal
The Netherlands kept online gambling formally prohibited for years, 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 out operators that had targeted Dutch players without a licence in the two years and nine months before applying, 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 from 30 June 2022; untargeted advertising (television, radio, outdoor, print) was banned from July 2023, leaving online advertising that people can opt out of and that must be shown to reach an audience at least 95 per cent aged 24 or over; sponsorship was phased out, other sponsorship ending in July 2024 and sports sponsorship in July 2025; advertising, bonus offers included, may not be aimed at 18 to 23-year-olds, and bonuses may not be offered during play or tailored to an individual's play. From October 2024, tighter deposit rules took effect: a player who wants to set a deposit limit of 350 euros a month or more (150 euros for 18 to 23-year-olds) can do so only by contacting the operator's staff trained in addiction prevention, and operators must run an affordability check before a player deposits, net, more than 700 euros a month (300 euros for 18 to 23-year-olds). Gaming tax, by then 30.5 per cent, rose to 34.2 per cent in January 2025 and to 37.8 per cent in January 2026, a two-step increase intended to raise revenue for 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 shows channelisation by spend falling slowly for several years, to an estimated 53 per cent in the second half of 2025, while more than nine in ten players still play at least partly with licensed sites, which suggests that players on unlicensed sites lose considerably more on average; the tax increase raised far less than forecast (a joint monitor by the finance ministry and the KSA in June 2026 estimated that tax receipts in 2025 were only 2 million euros above 2024, against a target of 108 million, as the tax base fell); and the coalition government in office in 2026, building on a KOA evaluation after which its predecessor had proposed raising the minimum age for the riskiest games to 21, set out plans in June 2026 for a ban on online gambling advertising including bonuses, an overarching deposit limit held in a central register and a stronger duty of care, while dropping the age rise for now; the draft bill is expected to go out for consultation in 2027. 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 of 37.8 per cent. And both are now under review, 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; Belgium has gone further than the Dutch advertising sequence (role models, untargeted, sponsorship), with a ban in principle on gambling advertising save for narrowly authorised forms, and sports sponsorship restricted from 2025, and the approach is 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 a one-euro default slot stake (optional tiers of up to five euros from July 2026 until the end of 2027), a five-second average game, 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, staff contact and affordability checks on higher deposits 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.