Possible relaxation of rules

The German online market developed in the logic of the strict "protective" model GlüStV 2021: for virtual slots there is a limit of 1 € per spin, a timer of at least 5 seconds, progressive jackpots, autospin and aggressive bonus mechanics are prohibited. Additionally, from 2021, a 5.3% turnover tax on bets was introduced, which economically puts pressure on the target RTP of games. These parameters combine to form a more "slow" and restrained game, but at the same time fuel the dispute about the inflow of the audience offshore.

Why the topic of mitigation is back on the agenda

1. Traffic channeling. Industry players and specialized associations point out: an excessively "tough" food regime makes the legal segment less attractive, which prevents the displacement of illegal immigrants. At the beginning of 2025, it was discussed that it was product restrictions that were among the key reasons for leakage into the "black" market.

2. Judicial and regulatory signals. In 2025, preparations were underway to update the Contract earlier than revision-2026 (in terms of execution tools). Against this background, the industry is also seeking to revise the controversial product parameters in order to strengthen the "white" channel.

Current RTP and Jackpot Position

RTP. The law does not set a direct "RTP minimum," but the 5.3% turnover tax and other restrictions forced some operators to reduce the actual payments for slots. The discussion about approaches (for example, switching to a GGR base or flexible RTP corridors) sounds like an economic, not just a legal issue.

Jackpots. Progressive jackpots are prohibited: this removes the "engagement anchor," but reduces the risk of "hot" behavioral outbursts. It is around jackpots that the topic of possible point mitigation most often arises.

Arguments "for" soft adjustment

Sewerage and tax revenues. A slightly more "marketable" product (without extremes) helps keep players in the licensed circuit and increase tax collection. This logic is also supported by regular industry reviews of offshore flows.

EU comparability. A number of EU jurisdictions use minimum RTPs and allow limited jackpots when strictly transparent accounting for prize contributions - this is often cited as an example for "fine-tuning" without destroying the protection of players.

Arguments "against"

Risks to vulnerable players. Increasing the speed of the game/expectations of jackpots can increase harm, which means it contradicts the goals of GlüStV.

Enforceability and control. Any "complex" mechanics (network progressives, dynamic RTP) requires additional regulatory and technical resources (audit, reporting, telemetry, test house).

Possible mitigation scenarios by 2026 (if there is political will)

1. Jackpots with hard fuses. Resolution of fixed or "capped" progressions (for example, with an upper prize limit, transparent percentage of accumulation, publication of reports and an instant log of contributions to the LUGAS subsystem).

2. RTP corridors and public metrics. The introduction of a minimum RTP threshold for slots (or a "corridor" for the portfolio), mandatory RTP publication and quarterly reports for GGL so that the market does not "go" to too low values ​ ​ due to the revolving tax.

3. Micro speed relaxation. Experimental reduction of the spin timer, say, from 5 s to 4 s in pilot lots of games for operators with impeccable compliance - for post-audit.

4. Dynamics of limits for "proven" players. Already today, exceptions to the deposit limit are allowed with in-depth verification (up to 10,000-30,000 € in a number of cases). A similar risk-base approach can be translated into product parameters (jackpots/speed) - only after a confirmed solvency and RG assessment.

How this can be put into practice

Pilots with sunset clause. Temporary permits (12-18 months) with KPIs by channel, RG indicators and complaints; automatic "rollback" if goals are not met.

A single control stack. Marking of jackpot traffic, dedicated audit of prize funds, GGL auto-alerts for RTP/accumulation anomalies.

Communication for players. Direct indication of RTP/jackpot contribution in the game interface + "RG badges" for pilot products.

What is already visible now

The political and regulatory discussion has really accelerated by 2025-2026: land ministers are promoting updates to the Treaty earlier than the planned revision-2026 (although the main focus is on execution tools and blocking), and DOCV and specialized lawyers are simultaneously raising the topic of clarity of deposit/rate limits and product restrictions. This does not mean automatic mitigation, but the window of opportunity for "fine-tuning" the RTP and jackpot modes is clearly wider than in 2021-2023.

Bottom line. Germany may consider limited, managed liberalization: accurate opening of fixed/capped jackpots, transition to RTP corridors with public reporting, and pilot easing of the spin timer - all this exclusively under the "hard RG circuit" of GGL and readily curtail experiments. This approach would support the goal of sewer without abandoning the principles of protecting players.