Daw Global: Weekly Brief - 7th September 2026

iGaming In The Federal Republic Of Germany

Insights by Martin Van Lessen – Strategic Director | LinkedIn

The Federal Republic Of Germany regulates online gambling under the Interstate Treaty On Gambling 2021 (GlüStV 2021), supervised since 01 January 2023 by the Gemeinsame Glücksspielbehörde Der Länder (GGL).

Licences for sports betting and virtual slot machines are issued nationally, while online casino table games are licensed by the individual states, and only five such concessions had been granted as of 26 May 2025.

A licensed virtual slot machine carries a maximum stake of EUR 1.00 per spin by default, an average game duration of at least five seconds, no jackpots and no automatic play, and every player is subject to a cross-provider deposit limit of EUR 1,000.00 a month.

Tax is charged on the amount staked rather than on the revenue the operator retains, at 5.30% of every stake placed on slots and on sports betting.

From 01 July 2026, the GGL has allowed licensed operators to raise the stake limit to EUR 3.00 and then EUR 5.00 for players meeting additional conditions.

Those limits are the reason the market draws offshore licensed operators, as demand for higher stakes and table games sits outside what the licensed offer provides.

The GGL's own study puts unregulated activity at around 23% of the online market in 2024, and enforcement runs through blocking orders against sites and instructions to payment service providers (PSPs), with 657 sites blocked from the Federal Republic Of Germany in 2024.

iGaming Business-To-Business (B2B) Providers

Insights by Paul Hill – Sales Director & iGaming Strategist | LinkedIn

An iGaming operator is the brand the player sees, and very little of what sits behind that brand is built by the operator itself. The B2B layer of the sector supplies almost all of it.

Platform providers build the system the site runs on, covering player accounts, bonusing and the back office. Game studios make the slots and table games, aggregators distribute content from many studios through a single integration, and sportsbook feed providers supply the odds, the markets and the trading behind a betting product.

Whether a supplier needs a licence turns on what it provides and where it provides it from, rather than on where the operators it supplies hold their own licences.

The requirement applies where the supply is indispensable to the outcome of a game or to the handling of essential regulatory data, which covers the platform and the content while leaving suppliers of non-critical services outside it.

Entering a further market more often means certifying each game with an independent test laboratory than holding another licence.

B2B providers are typically paid a percentage of the gross gaming revenue (GGR) their platform or their content generates, meaning player stakes less player winnings.

That share is calculated once the calendar month closes and invoiced to the operator for the month just completed, so the provider is paid in arrears rather than as the activity happens.

Source Of Funds (SOF) And Source Of Wealth (SOW)

Insights by Richard Picton-Turbervill – Co-Founder & Director | LinkedIn

SOF and SOW are asked for at onboarding and are routinely confused, and the confusion costs applicants time.

SOF is where the balances moving through the bank account come from. SOW is how the people behind the business came to hold the assets they hold, and it applies to the ultimate beneficial owners (UBOs) rather than to the company.

For the company, SOF is evidenced by the contracts held with the counterparties funds arrive from and the statements that show those funds arriving, so an operator provides its processing and settlement statements alongside the agreements behind them, and a broker-dealer provides the same for its client deposits and its liquidity providers.

Audited accounts and the capital the company started with sit alongside, with the documentation showing where that capital came from.

For a UBO, SOW is evidenced by whatever built the position, and the answer differs from one owner to the next.

The sale of a previous business is shown by the sale agreement and the completion statement, employment income by contracts and tax returns, and dividends from other holdings by the accounts of the companies that paid them.

Both are asked for once at onboarding and refreshed only where the ownership changes or the activity moves away from what was declared, so a file assembled properly at the outset is rarely re-opened.

Applicants who prepare both before applying move through the onboarding and account opening process much more efficiently.