
What does Germany’s Interstate Treaty really say about online stake limits?
Are online stakes limited to just €1,000 per month and are player losses also capped?


German gambling regulation was shrouded in further mystery this week after the 16 federal states agreed to allow operators to provide services in the country until the new Interstate Treaty (IST) goes live.
Nobody quite knows which regulatory framework operators will be working to on this interim basis, before official licences are awarded as part of the new-look IST from 1 July 2021.
The states of Berlin and North Rhine-Westphalia are leading the way on the part-time regulation, but the results of their discussions have not yet been published.
However, the below sets out what we do already know about sports betting stake limits under the existing Interstate Treaty.
Stake limit legislation on sports betting licences
According to DLA Piper, the maximum stake per player may not, in principle, exceed €1,000 per month.
This limit can however be increased, although operators are not permitted to advertise the possibility of an increase.
An increased limit of between €1000 and €10,000 may be set, provided the player proves their economic capacity to the operator via income tax assessments or bank statements. This proof must be repeated by the player on an annual basis.
A specific numbered stake limit must be set for the individual player and he or she will be protected by an individual loss limit of a maximum of 20% of the newly agreed increased stake limit.
The operator must then monitor the player for potentially harmful behaviour and anonymously submit the results of the monitoring process to the supervisory authority twice a year.
There is also a third option, where the stake limit can be set up to €30,000, although this can only apply to 1% of an operator’s customer base.
In this case, the player must be at least 21 years old and the monitoring process must be more detailed, with the firm required to submit a report on a quarterly basis instead of bi-annually.
A stake limit in excess of €30,000 cannot be set.