Most regulated markets license the company and let certified games follow. Germany does both, and the second half is the unusual part: under the Glücksspielstaatsvertrag 2021 a virtual slot machine needs its own permission from the Gemeinsame Glücksspielbehörde der Länder before a licensed operator may offer it at all. A studio can hold a perfect operator relationship, a certified build and a live integration and still not be able to put a title in front of a German player, because the permission attaches to the individual game.
That changes the shape of a release plan. The German rules do not only ask whether the maths is sound. They ask how long a spin lasts, what a win is allowed to be, what the player is shown before the first stake, what happens when a risk feature opens, what the game calls itself and what the supplier has to hand over for review. The GGL publishes the detail in its Merkblatt für Anträge auf Erteilung einer Erlaubnis einzelner virtueller Automatenspiele im Internet of June 2026, written against § 22a GlüStV 2021, together with its decision guideline of 1 July 2026 on the stake limit. This article works through what those documents require of a game and of the supplier behind it.
Germany permits the game itself, not only the operator
The operator permission is the older, more familiar layer. A company that wants to host virtual slot machines in Germany needs the host licence under § 4 (1) and (4) GlüStV 2021, and the licensed provider is then listed on the GGL’s whitelist. The game permission sits on top of it and is granted separately, title by title.
§ 22a (1) sentence 2 puts it plainly: holders of a licence to host virtual slot machines “may only offer a virtual slot machine if it has previously been permitted on their application by the competent authority”. Sentence 3 adds the mechanism — “a version of the game must be made available to the authority for the purpose of reviewing the grant of the permission” — and sentence 4 sets the change rule: “material changes to the virtual slot machine after a permission has been granted require the permission of the competent authority.” Sentence 6 states the consequence for anything outside that process: an unpermitted virtual slot machine is unauthorised gambling.
The June 2026 Merkblatt spells out how that reads in practice. Alongside the host licence, “it is necessary that each virtual slot machine of a provider … is examined and permitted individually”, and “the permission of individual games is not granted without a host licence”. A supplier cannot start the game-permission track first and hope the operator licence catches up.
That sequence has a commercial edge. A title is not portable in the way a studio may expect: the permission runs to a licensed operator and to a named version of a named game. When a title moves to a different licensee, or when the game itself changes in a way the GGL treats as material, the paperwork starts again. The Merkblatt names what counts: “all statutory requirements under § 22a GlüStV 2021, such as HGW, spin duration and maximum stake” — the top-prize probability, the spin duration and the maximum stake — each require a fresh permission, while “a change to the RTP is to be notified”. Version control stops being a release-management nicety and becomes part of the licence. The version number is one of the fields the supplier must declare in the submission, which is the point at which a studio discovers whether its build identity is real. The same discipline is what an audited certification pack exists to support, though Germany asks for it per title rather than per platform.
The design constraints that are settled before the maths
Four of Germany’s requirements reach into the game model rather than the documentation, and each of them is a design decision a studio has to make early.
A win is a fixed multiple of the stake. § 22a (8) sentence 1 requires that “a win must consist of a multiple of the stake determined before the start of the game”. The Merkblatt is explicit about the corollary: “game designs in which the multiple of the stake varies as a win in the course of the game are inadmissible.” A round in which the value of the outcome is still moving when the player commits does not fit the model, however the maths is arranged afterwards. Wins and stakes are also euro-and-cent only — § 22a (5) forbids converting amounts into other currencies, points or units before, during or after the game.
Nothing accumulates into a prize for later. § 22a (8) sentence 2 is the jackpot prohibition: stakes, wins or parts of them “must not be accumulated for the purpose of creating wins for future games”. A progressive pot fed by every spin is not a feature that can be switched off in the German build; it is a model that has to be absent from it.
The pace is fixed. § 22a (6) sentence 1: “a game must last an average of at least five seconds.” Sentence 2 defines the interval — “a game begins with the declaration within the meaning of paragraph 4 sentence 1 and ends with the display of the result” — so the clock covers the outcome animation too. The Merkblatt states the corresponding ceiling: “a maximum of 120 paid games in 10 minutes is possible for the licence holder.” And § 22a (4) sentence 2 prohibits “program flows that start a further game independently after the previous game has run out” as well as “declarations by a player to take part in several games in a row”: an autoplay control that offers a set number of consecutive spins is prohibited, not merely discouraged.
One game at a time, in front of the player and on the screen. § 22a (10) sentence 1 prohibits “the simultaneous playing of several virtual slot machines”, sentence 2 extends that to the same game, sentence 3 requires licence holders to enforce it “by suitable technical measures”, and sentence 4 states that “only one game may be shown to the player at the same time”. The Merkblatt adds the naming rules that go with it: the name of the game “must be displayed at all times during the game”, and it “must not be misleading, in particular not use the name of games that actually exist if their rules do not apply to the game”.
Two more constraints are worth reading as build requirements rather than advertising ones. § 22a (11) makes the words “Casino” and “Casinospiele” inadmissible “in connection with the hosting and the own distribution of virtual slot machines or advertising for them” — including inside the product. And § 22a (12) allows hosting “only over the internet”, with stationary distribution of a virtual slot machine prohibited, so a retail or terminal variant is not a licensed surface.
What the player has to be able to see before staking
§ 22a (3) sentence 2 requires that “the game rules and the prize plan must be easily callable and be described in a way that is easy for the player to understand”. Sentences 3 and 4 then name the two figures that have to be visible: “the probability of winning the top prize and the average payout ratio per one euro staked” have to be shown to the player recognisably, and “the display must be made where the stake can be placed”.
The Merkblatt pins down what the top-prize figure means, because the easy version of it is not the required one. The stated probability has to be “at least the probability for the win that results as a sum when the highest possible symbol values are present on all played win lines at a standstill of the reels, without taking account of further additional win possibilities from other aspects of the game”. The rules must say which situation the figure refers to and, where it applies, that higher wins remain possible with a lower probability — and “the display of the top-prize probability cannot be replaced by the display of the probability of a win (line win, including small wins)”.
Three further details follow from the same section:
- Multipliers have to be exhaustive. “Multipliers reachable in a game must be listed exhaustively; stating a range is not sufficient.”
- The prize plan has to be arithmetically honest. “The wins stated in the prize plan must correspond to the actual wins depending on the chosen stake.”
- The rules have to describe the geometry of a win. The explanations of the symbol combinations that trigger a win on the played win lines or win ways “must make a statement about the direction and the start of the evaluation and the requirement of the connection of the combinations (gaps)”.
The language rule is part of the same obligation. The Merkblatt requires the rules and “the entire design of the game” to be in German and comprehensible, with an exception only for “terms that are also customary in the industry and understandable for players and first-time players”, which must be translated or explained in a suitable place. A slot shipped in Germany is not a localised build in the marketing sense; it is a German-language artefact with an English-derived vocabulary the authority will read.
Findability is treated as a design property too. The prize plan and the rules have to be “designed to be easily callable through unambiguous labelling and visual presence as a whole”, which the Merkblatt reads as a permanently present button with a clearly understandable name, with the rules and the prize plan then “completely and without further steps” reachable — ideally both a short and a long form behind one control. That last sentence catches a common build: a help panel that opens a second modal, or a rules screen that renders the prize plan only after a tab is selected.
Risk games and free spins are permitted, with conditions attached
The optional gamble feature is not banned. The Merkblatt treats risk games “in principle as a permissible component of a virtual slot machine” — a ladder or a card-colour double-or-nothing round may be licensed — but the conditions are specific:
- The sequence has to be explained in the rules, and “the actual probability distribution must be explicitly pointed out during play itself”.
- The graphic design “must not convey an impression that contradicts the probability distribution”.
- A card risk game “must warn that the number of suits of the cards dealt has no influence on the colour of the next card”.
- Risk games “must be clearly named and identifiable as such”.
- The feature “must be included in the average payout ratio”, and that has to be pointed out alongside the probability distribution.
- A risk game may not be based on skill, nor may its presentation suggest that it is, and it “may not create a pressure situation for the player” — the Merkblatt gives the example of a risk game that ends after a short time “without further input by the player and without a result”, and applies the same rule to the choice of whether to play a risk game at all.
Free spins are held to the same standard as paid spins. The only difference the Merkblatt allows is that “the stake for a free spin is not connected to a money flow from the player’s account”; everything else — the disclosure, the probability figures, the risk-game rules inside the free-spin round — is unchanged. A bonus round that awards free spins with a hidden distribution is not a lighter case than the base game.
The stake limit and what changed on 1 July 2026
§ 22a (7) sentence 1 sets the default: “the stake may not exceed one euro per game.” Sentence 2 gives the authority the power to adjust that figure “to changed circumstances in order to achieve the aims of § 1”.
On 1 July 2026 the GGL used that power. Its Entscheidungsrichtlinie zur Anpassung des Höchsteinsatzes permits a tiered departure from the one-euro rule, “at the latest until 31 December 2027”:
| Stage | Stake per spin | What the player has to have done | What the operator has to run |
|---|---|---|---|
| Default | up to €1 | nothing beyond the ordinary account requirements | the ordinary monitoring under § 6i (1) |
| Stage 1 | over €1 up to €3 | reached the age of 21 | the ordinary monitoring under § 6i (1) |
| Stage 2 | over €3 up to €5 | reached 21 and completed a 90-day qualification period with no conspicuous play behaviour | a special limit monitoring, with anonymised results and its evaluation sent to the authority every quarter |
Stage 2 carries three further obligations that sit with the operator rather than the game: players whose limit monitoring indicates a risk of gambling addiction must be reported to the supervisory authority every quarter with the indications and the measures taken; the player’s consent to that processing has to be obtained before the limit is raised and maintained afterwards; and the GGL’s provider FAQ confirms that “the introduction of increased stakes is voluntary” and that “there is no entitlement to the grant of an increased maximum stake”. A player who meets the conditions can be admitted straight into stage 2, but the 90 days still have to have run — the FAQ gives the example that a player who has shown no conspicuous play behaviour since 1 July 2026 completed the qualification period on 29 September 2026.
The stake limit is only the outer edge of what a German build has to support. Above it sits the cross-provider deposit limit: § 6c (1) sentence 2 provides that the cross-provider monthly deposit limit “must in principle not exceed 1,000 euro”, sentence 6 states that “if no cross-provider deposit limit has been set for a player, play must not take place”, and sentences 3 to 5 allow the licence to permit a different amount. The GGL’s published answers describe the shape of that: increases up to €10,000 per month, and a band from over €10,000 up to €30,000 available for “no more than 1% of the players active with the respective provider”, measured on the average of the previous three months, with economic capacity evidenced by tax assessments, income documents or bank statements rather than by the player’s own statement.
None of this changes the game’s maths. It changes what the game’s interface has to be able to express, because the stake control in the build has to be able to sit at €1 for an ordinary player, at €3 for a 21-year-old in stage 1, at €5 for a player in stage 2, and to reflect a limit that the platform, not the game, owns.
The dossier that goes in, game by game
The permission is applied for, not certified into existence. The Merkblatt states that “compliance with the requirements of § 22a GlüStV 2021 does not have to be proven by a certificate”, adding that “existing certificates can, however, be submitted” — so a laboratory report is evidence, not the permission. The application for individual games consists of the application form for the permission plus an Excel table, submitted “in paper form” and “in digital form”, by “the legal representation in the permission procedure or the legal representative, naming the applicant”.
The table is the interesting artefact, because its columns are the licence’s field list. Each row is one game, and the Merkblatt requires all columns to be filled:
- Name — “the concrete name of the requested game, as shown on the game screen”, as exactly as possible including punctuation and name additions. Each game must carry a different name, “the multiple use of a name is not permitted”, and provider-specific additions in the name field are not permitted — they belong in their own column.
- Developer and contractual partner — the second “does not have to be the developer”, which is how an aggregator’s title is declared.
- Provider — the gambling provider’s name or the relevant sub-brand.
- Game form — “virtuelle Automatenspiele”.
- Game area URL — “the complete URL (transfer protocol, subdomain, domain and directory path) that leads to the relevant area”.
- Average spin duration, HGW (the top-prize probability shown at game level), maximum stake, RTP, version number and LUGAS ID — “the designation under which the games are kept in the data transmission on the safe server”.
- Risk game and risk game type — whether the game is submitted with a risk game and which kind it is, ladder or card.
The formatting rules are not cosmetic either: developer studios sorted alphabetically, games within a studio sorted alphabetically, and “implementation of a filter function”.
Then the game itself has to be reachable. “A test environment must be set up by the gambling provider” for the authority to review the requested games, with “functional user accounts … with which the authority can review each game in its full functional scope”, access data transmitted, and the Merkblatt asking for “several accesses (e.g. 10) with sufficient (e.g. 1,000 euro) balance” to speed up the review. That is the point at which a build’s staging story matters: an environment that cannot reach every round, every bonus state and every risk-game branch in reviewable form is an environment that holds up the permission. The RNG evidence behind the maths goes in the same submission, as test reports and certificates on the random number generators used, presented “within the framework of the IT security concept”.
Where the supplier’s contract meets the licence
One paragraph of the Merkblatt matters more to a studio than to an operator. Where agreements exist or are concluded with third parties in relation to the game — “in particular with, but not limited to, so-called ‘B2B’ operators of online gambling platforms” — the supplier has to ensure that “the licence holder remains the contractual partner of the player and, as such, also exercises rights and duties from the contract itself”, unless the permission, a statute or a statutory instrument provides otherwise. Contracts with third parties “are to be presented to the supervisory authority before the business operation begins”.
Read commercially, that settles a question that surfaces in every aggregation deal in the market: in Germany the player contracts with the licensed operator, not with the studio or the aggregator sitting behind it. The aggregator appears in the submission as the contractual partner in the game’s row, which is where the distribution chain becomes visible to the authority, but it does not become the player’s counterparty. The aggregator model works in Germany; it works with a named licence holder at the front of it. Germany is not the only market that asks for per-title evidence — the Italian certification timetable runs on the same per-game logic — but it is one of the few where the disclosure text, the pace of the spin and the stake ceiling are all part of the same game-level permission.
What a German release plan has to sequence
Put in order, the dependencies look like this. The operator licence first, because a game permission is not granted without one. Then, per title: the design decisions that cannot be changed later without a new permission — spin duration, maximum stake, top-prize probability, risk-game presence and type, game name and game area URL — settled before the maths is frozen. Then the dossier, with the version number that the build will actually carry. Then the test environment that the authority can review in full. Then the notification routes for what does not need a new permission, of which the RTP change is the named example.
The failure mode this prevents is a release calendar built on the assumption that a certified game is a licensed one. In Germany the certification of the maths, the permission of the title and the licence of the operator are three separate things, and only the last of them is about the company. If you are commissioning or supplying a title for a market that examines games one at a time, our certification and compliance work is the part of the build that starts first. None of the above is legal advice; the GGL’s own documents and the Glücksspielstaatsvertrag 2021 are the authority on what a specific title needs.
Questions suppliers ask
Does every virtual slot game need its own permission in Germany?
Yes. § 22a (1) sentence 2 provides that holders of a licence to host virtual slot machines may only offer a virtual slot machine if it has previously been permitted by the competent authority on their application, and the GGL’s June 2026 Merkblatt states that each virtual slot machine of a provider is examined and permitted individually. The permission for an individual game is not granted without a host licence, and an unpermitted virtual slot machine counts as unauthorised gambling under sentence 6 of the same provision.
How long must a spin last, and how many spins are allowed?
§ 22a (6) sentence 1 requires a game to last “an average of at least five seconds”, measured from the player’s declaration to the display of the result. The GGL’s Merkblatt states the corresponding ceiling of “a maximum of 120 paid games in 10 minutes”. Autoplay controls are prohibited: § 22a (4) sentence 2 rules out program flows that start another game by themselves and declarations to take part in several games in a row.
What exactly has to be shown as the top-prize probability?
The probability of the win that results as a sum when the highest possible symbol values lie on all played win lines at a standstill of the reels, without taking account of further additional win possibilities from other aspects of the game. It has to be shown at the level where the stake is placed, together with the average payout ratio per one euro staked, and it cannot be replaced by the probability of a win including small line wins. The rules also have to say which situation the figure refers to and, where it applies, that higher wins are possible with a lower probability.
What changed for stake limits on 1 July 2026?
The default remains one euro per spin under § 22a (7) sentence 1. Since 1 July 2026 the GGL’s decision guideline permits a tiered departure from it, at the latest until 31 December 2027: over €1 up to €3 for players who have reached 21, and over €3 up to €5 where the player has also completed a 90-day qualification period with no conspicuous play behaviour and the operator runs a special limit monitoring and reports its anonymised results and its at-risk players to the authority every quarter. Offering the increase is voluntary and there is no entitlement to it.
Can a game with a ladder or card gamble feature be licensed?
It can, and the Merkblatt treats risk games in principle as a permissible component of a virtual slot machine. The sequence has to be explained in the rules, the actual probability distribution has to be pointed out during play itself, the design must not contradict that distribution, the feature must be named and identifiable as such, it must be included in the average payout ratio, it may not rest on skill or suggest that it does, and it may not create a pressure situation — including by ending without a result after a short time without further input from the player. A card risk game also has to warn that the number of suits dealt does not affect the colour of the next card.
Does the supplier become the player’s contractual partner?
No. The Merkblatt requires that the licence holder remains the player’s contractual partner and exercises the rights and duties from that contract itself where third-party agreements exist — in particular with B2B operators of online gambling platforms — unless the permission or a statute provides otherwise. Contracts with third parties have to be presented to the supervisory authority before business operations begin. The aggregator or studio appears in the submission as the game’s contractual partner, not as the party the player contracts with.
