Comparison with Great Britain and Germany

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1) Overview: Europe's three different approaches

France, the United Kingdom and Germany present three models of state control of gambling:

France - "limited and centralized": licenses are issued by ANJ, only bets, poker and lotteries are allowed; online casinos are prohibited.
The UK is "liberal and marketable": almost all forms of gambling are allowed under a UKGC licence, including online slots, live games and casinos.
Germany is a "regional compromise": it is regulated at the land level, there are federal frameworks (Glücksspielstaatsvertrag), betting and poker are allowed, and online slots with restrictions.

2) France: limited legalization and fiscal emphasis

The French system is built on the principle of "allowed by exception."

Online games are legal in only three categories - betting, poker, lotteries.

Online casinos (roulette, blackjack, slot machines) are prohibited.

The regulator is the Autorité Nationale des Jeux (ANJ), which has been the same for all formats since 2020.

Taxation is high: cumulatively up to 59% PBJ (GGR) on online rates and up to 63% on lotteries.

Casinos work only offline, under the control of the Ministry of Internal Affairs.

France's focus is consumer protection and social responsibility, not market expansion.

3) UK: open and globally oriented market

Regulator - UK Gambling Commission (UKGC).

Licenses are available for all forms of online gambling: slots, roulette, poker, betting, live games.

Operator requirements - RTP transparency, data protection, advertising control, Responsible Gambling programs.

Taxation is milder: Remote Gaming Duty - 21% GGR, rates and lotteries are taxed separately.

Advertising is allowed, but strictly labeled (18 +, risk warnings).

The British model is considered the most mature in the world, combining innovation (VR, crypto, AI) with strict compliance practices.

4) Germany: federalism and land compromises

Since 2021, Glücksspielstaatsvertrag 2021 (GlüStV) has been in effect - a new interregional land agreement.

Allowed: online poker, betting and online slots, but with strict restrictions:

€1 limit per spin, no autospin, mandatory pauses and deposit limits, game time control.
The regulator is Gemeinsame Glücksspielbehörde der Länder (GGL), based in Halle.
Taxation: 5.3% of the turnover of bets on slots and poker, which makes the model sustainable, but limits the profits of operators.
Advertising is limited in time and channels (prohibited in children's and morning TV).

Germany follows the path of "dosed legalization" - control is higher than in the UK, but more liberal than in France.

5) Comparison of key parameters

Parameter	France (ANJ)	UK (UKGC)	Germany (GGL)
Online casino	- Prohibited	+ Allowed	+ Restricted
Online rates	+ Allowed	+ Allowed	+ Allowed
Online poker	+ Allowed	+ Allowed	+ Allowed
Lotteries	+ Monopoly FDJ	+ Multiple operators	+ State
Regulator	ANJ (single)	UKGC	GGL (Federal)
GGR taxes	~ 45-60% (high)	21% (moderate)	5.3% of turnover
Primary objective	Soc. protection, RG	Equal market, innovation	Control and balance
Online slots	- No	+ Yes	+ Yes, limits
Advertizing	Severely restricted	Allowed with label	Time limited
Self-exception	National Registry	GAMSTOP (single)	Sperrdatei OASIS

6) Principles of regulation: philosophy of three systems

France is a priority for harm prevention and fiscal discipline. Games are a socially controlled product, not a mass service.

Great Britain - a bet on responsible market freedom, where the player is informed and protected, and the operator carries reputational risks.

Germany - finding a compromise between control and income, with a focus on transparent limits and federal equilibrium.

7) Economy and Market (data 2024-2025)

France: the PBJ market is about €14 billion, of which 50% are lotteries and 35% are bets.

UK: over €20 billion PBJ, the largest online segment in Europe.

Germany: about €10 billion PBJ, a fast-growing online market after GlüStV.

France remains the most conservative, but also the most socially protected jurisdiction.

8) Trends 2025-2030

France: It is possible to discuss the partial legalization of online slots (in a limited form) under the control of ANJ.

UK: strengthening of Responsible Gambling norms (limits, AI-monitoring of behavior).

Germany: market stabilization and a possible reduction in turnover tax to increase competitiveness.

France is a strict and socially oriented model (online casinos are prohibited).

The UK is an open market with moderate taxes and strong self-regulation.

Germany is a federal compromise: online casinos are allowed, but with strict limits.

The French system provides maximum protection for players, but limits innovation and competitiveness in Europe.