purpose of taxation, etc. However, we could question the efficiency of such tools, especially with crypto payments becoming more popular day by day. So, what can Bundestag do to avoid German punters looking for alternative casinos? The answer would be to adjust the regulations to make the gambling market more attractive, competitive, and, dare I say, realistic as well. The biggest surprise since the launch of the German market has been that nobody hurries to acquire local gambling licensure. To put this in numbers – less than 40 operators applied for local licenses, which is a very low number, considering that Germany is one of the highest-rated gambling markets in Europe. Moreover, most of these licensed operators are land-based casinos, and I believe it is clear to everyone that they had no other way but to get German licensure in order to continue operating on the market. The surprising remaining factor is that the applications for requesting German licensure do not increase, especially when it comes to online casino sites. It is also interesting that the regulator has not yet started licensing the casino side (online slots, online poker, other online casino games), which I will discuss more thoroughly below. Before that, let us look at the situation of the so-called regulated sportsbook sector. Once again, the local regulator currently licenses less than 40 operators. The research conducted by the Deutscher Sportwettenverband (DSWV) in February 2022 showed that there are more than 500 online gambling sites currently operating on the market without German licensure and freely accepting German punters. As Mathias Dahms, the president of the DSWV, explains, “Sports betting sector has long since arrived in mainstream society and the ISTG 2021 did ease the previous strict prohibition policy in this gambling sector.” However, for every legal provider, there are multiple providers without permission, and the operators working within the regulatory framework are constantly being let down by a lack of action from the authorities against the black market. Thus, even though the licensing of the sportsbook section already started, there is a chain of problems that remain unresolved, and ways of actively solving them have not yet been found. The uncertainty regarding licensing the casino side remains unchanged. So far, no German online operator has a fully licensed casino side. We will be able to see online operators that have = slots and online poker sides licensed by the end of this year. Again, the German gambling infrastructure is not at all ready to adapt to the regulations brought by the ISTG 2021 smoothly. That is why we, the team of NoLimit-Casinos.De, are closely observing the ongoing situation and looking forward to the changes we may see quite soon. This period is rather crucial as we may witness a chain of surprises that come along with these processes. In particular, we presume that eventually, the regulator will have to mitigate the regulations regarding online slots if it wishes the new treaty to work properly and have a successful future. What should affiliates know/consider before trying to break into the German market? My key advice would be to “thoroughly research the market.” As the ISTG 2021 is still a new treaty and the German market itself is still in its emerging stage, there is a significant information gap that leaves players in a vacuum, not knowing what to do or what to expect next. Therefore, researching the market and providing them with trustworthy, relevant information is of the biggest priority now. That is what we Nolimit-casinos.de are doing and I have to say, it is working effectively. CLOUDS OF CONTROVERSY IN GERMANY Michael Schumann is author and co-founder of NoLimitCasinos.de, the independent affiliate website that aims to help German punters make an educated decision when selecting online casinos. Nolimit-casinos.de has been part of GamAffiliates operating in the Gambling Vertical globally since 2020. Even though the licensing of the sportsbook section has already started, there is a chain of problems that remain unresolved, and ways of actively solving them have not yet been found. G P W A t i m e s . o r g 34
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