Gemeinsame Glücksspielbehörde der Länder, the Federal Gambling Authority of Germany, has issued a direct response to consumer questions related to the Cross-State Gambling Supervision System.
The Federal Authority has published an ‘FAQ section’ on its website in response to ‘common questions’ about LUGAS functions and how its deposit limit rules are applied across German states, restricting individual spending and activities in online gambling.
The notice references consumer questions such as: “Why do I have a cross-provider deposit limit? Can I have my limit deleted? Can the authority change my limit? Why can’t I play?”
LUGAS’s supervision of cross-provider deposit limits is required by federal law, as mandated by the rules of Germany’s Fourth Interstate Treaty on Gambling – the GlüNeuRStv regime.
All GlüNeuRStv licensed operators must inform new and existing customers to set their cross-border monthly deposit between €1 and €1,000. GGL recognises that deposit exceptions can be made for ‘special occurrences’ which must be documented by licensed operators.
Once verified by LUGAS, customers can change their deposit limits ‘at any time’. However, GGL notes ‘an increase in deposit limits only takes effect after a period of seven days’.
The regulator continued: “Legally, this deadline is calculated so that the increase takes effect at the end of the seventh day after the day of the limit increase.”
Consumers were informed that the LUGAS cross-provider deposit system functions independently of deposit, stake, or loss limits protections offered by individual operators.
GGL cannot set individual limits on deposits, as GlüNeuRStv-licensed operators carry the responsibility of “issuing increased limits” across websites – as the “setting and changing of cross-operator limits is managed by the provider”.
Customer deposits will be restricted once “the cross-provider limit has been reached”, and “remaining balances are irrelevant.” Operators must maintain a record of customers’ failed deposits.
GGL will not address customer complaints about cross-provider limits; which must be directed to individual operators.
Consumers were reminded that cross-provider limits are applied every month, as ‘deposit amounts are restored to the customer’s desired amount from the first day of the month’.
The use of a cross-provider deposit limit has been criticised by the German Online Casino Association (DOCV) as a barrier to effective customer safeguards provided by individual operators.
Last month, at a meeting of gambling stakeholders in Dusseldorf, the DOCV demanded that GGL implement ‘instant corrections’ to the GlüNeuRStv regime.
Advocating for immediate changes, DOCV emphasised that GlüNeuRStv has not fulfilled its primary objective of developing a “controlled central system to protect consumers from online gambling threats”.
The leadership of GGL has stated that it recognises concerns about GlüNeuRStv limitations. Yet, its regulatory focus remains on strengthening the Interstate market against black market infringements, improving player protections and carrying out a review of advertising laws.
