Investigative Report Finds Loopholes in German Gambling Rules

Germany’s Fourth Interstate Treaty on Gambling (GlüNeuRStV) is under scrutiny after an Investigate Europe report alleged state governments have circumvented regulations to allow operators to bypass financial checks and enabling illicit gambling.
The report, titled “Legal, illegal, doesn’t it matter?”, claims federal states permitted online gambling companies to override the €1,000 monthly deposit cap by using Schufa-G credit checks instead of stricter financial assessments. Critics argue this undermines consumer protections and allows players to gamble large sums without proper income verification.
Allegations of Bypassed Financial Checks
Since July 2021, GlüNeuRStV rules have required licensed operators to enforce a €1,000 deposit limit, with exceptions up to €10,000 if a player’s income is verified. However, a “secret agreement” allegedly enabled operators to use Schufa-G checks, which critics, including Bremen Senator Ulrich Mäurer, have called a “bogus credit check.”
Legal concerns have grown following a case where a customer lost €30,000 gambling on Tipico after being assessed via Schufa-G. The Regional Court of Lüneburg ruled that Schufa-G checks “do not meet legal requirements” for proving financial stability, which adds further doubts about their legitimacy.
Investigate Europe claims around 300,000 players have been approved for deposit limits above €1,000, with the number rising. Additionally, live betting, which is banned under German law, remains available due to legal loopholes.
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DSWV Defends Schufa-G Checks
The Deutscher Sportwettenverband (DSWV) dismissed the allegations as an “unfounded scandalization” and denied any secret agreements saying that settlement details were publicly available.
DSWV insists Schufa-G checks “help prevent excessive debt” but acknowledges flaws in the LUGAS system. The association submitted reform proposals in August 2024 to address regulatory inconsistencies.
Amid the controversy, DSWV has warned of a growing black market gambling problem. German media reports have repeatedly claimed that 1.3 million Germans suffer from gambling addiction. However, DSWV disputes this figure and points to research from economist Günther Schnabl.
The organization has highlighted a decline in legal gambling participation, from 55% in 2007 to 30% in 2021, while over 50% of gamblers now use unlicensed operators. As such, DSWV is calling on lawmakers to address black market risks instead of imposing ineffective regulations on legal operators.
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