What are these changes going on in the German market?

[Tupee]

Started receiving emails form various affiliate programs that I have to stop advertising for German players or need to change the way I present a site. What is this new regulation taking place, can you summarize it briefly? I find no info on it.

 

[melcb]

And they havent given us much time to make these changes I feel like we just got over the hurles of UK compliance and now this...

This is our summary so far:

German Compliance Requirements & Toleration Criteria

Germany intends to implement an online slots licensing regime for commercial operators, introducing a raft of new measures designed to promote social responsibility and minimise gambling-related harm.

The new rules will officially come into effect in July 2021, after which the relevant licences can be issued. In the meantime, there will be a policy of transitional tolerance, whereby operators can engage with the German market provided they adopt the new regulatory measures. Those that ignore the new regulations may be excluded from the future official licensing procedure.

Starting on October 15th, due to further restrictions imposed by the State Treaty on game play, there will be a limited games list made available for Germany

Affiliates need to do the following changes to comply with these new regulations:

The changes apply to:

• Affiliates that have a .de domain; and/or
  
  
• Affiliates that promote in German; and/or
  
  
• Affiliates that have specific lists such as DE/German casinos lists.
  
  
• Affiliates that geo-target will pose a different challenge. In such cases, where the DE flag is visible or there is a clear indication that the targeted audience is DE

Deadline to make changes: 15 October 2020

1. Live Casino, Table Games, Jackpot Games are no longer permitted (i.e. Blackjack, Roulette, Baccarat, Live Casino games in general etc')

What you need to do:

The following items and terms must be removed from all your affiliate content in relation to our brands (this only applies when the content is in relation to the applicable casino brands):

1. Change the terms “Casino” and “Kasino” to spielbank

2. Remove the term Jackpots

3. Remove the term Table Games

4. Remove the term Scratch Cards

5. Remove the term Live Games

6. Remove the term Poker

7. Remove the term Roulette

8. Remove the term Baccarat


1.2) Images of blackjack tables, roulette tables or any kind of live casino and/or table game, jackpot games, jackpot amounts/total jackpots amounts are not allowed and need to be replaced or removed in relation to our brands.


2) You cannot use the word ‘casino’ or ‘kasino’ or ‘Casinospiele’ except when mentioning the brand name i.e. 666 Casino. We have been told that you may use the word “spielbank when referring to a casino, as in "the building" or the "entity" itself

Slot products for Germany can be referred to as “Automaten Spiele”

Under the new guidance, "casino" can only be used in reference to a land-based casino.

2.1) You can’t have the word ‘casino’ written in a different format, e.g. Kasino, Qasino, Cesino, C@asino. Any wording similar to the word will be completely prohibited (the brand name Cozino is still permitted).

3) If you show a logo – it should not include the word ‘casino’ in the image

4) Free to play demo games are not allowed, and therefore any mention of Free to Play Games is also to be removed from any content material.

5) Pre-paid PaySafe Cards will not be accepted as a payment method and therefore would need to be removed from any content. Players, however, will still be able to use the PaySafe wallet.


German Bonuses


Significant terms to use:

English: 18+. T&Cs Apply. Gamble Responsibly. Gamblingtherapy.org

German: 18+. T&Cs Apply. Verantwortungsbewusstes Spielen. Geschäftsbedingungen gelten. Gamblingtherapy.org

• Players cannot deposit more than €1,000 per month, per brand.
  
  
• Auto play must be disabled on all games.
  
  
• Reality check every 60 minutes, with a 5-minute cool off period before play can resume.
  
  
• 'Panic button' to be displayed at all times, which allows players to instantly exclude themselves from the casino.

Programs that have emailed to make these changes by 15 Oct

• DreamTeam Affiliates
  
  
• SkillonNet Brands (cozino)
  
  
• Bigwin Affiliates
  
  
• Fruity Affiliates
  
  
• Netgamingsolutions
  
  
• Branders
  
  
• 21/Twenty One Affiliates
  
  
• Playgrand affiliates
  
  
• Ivy Affiliates
  
  
• Bet365
  
  
• EgamingOnline / EGO

• Genesis Affiliates

• DreamTeam Affiliates

• Bet-at-home

• Wild Affiliates (Wunderino, Hyperino, and mybet)
  
  
• CasinoClub

What you need to do:

The following items and terms must be removed from all your affiliate content in relation to applicable brands

• Change the terms “Casino” and “Kasino” - on german site it can be referred to as Spielbank
  
  
• Remove the term Jackpots
  
  
• Remove the term Table Games
  
  
• Remove the term Scratch Cards
  
  
• Remove the term Live Games
  
  
• Remove the term Poker
  
  
• Remove the term Roulette
  
  
• Remove the term Baccarat
  
  
• Remove any reference to Free to Play game
  
  
• Remove any reference to Pre-paid PaySafe Cards
  
  
• Remove all promotional material/banners for casino products such as landing pages and banners that you have acquired through our affiliate system from all German facing websites.

 

[nibnab]

The operators are going crazy. Everyone seems to have their own idea on how to stay compliant. Is there some official German resource for this regulation?
All the "news" websites are missing links to resources.

 

[riih]

The operators are going crazy. Everyone seems to have their own idea on how to stay compliant. Is there some official German resource for this regulation?
All the "news" websites are missing links to resources.

Its the same thing every time - happened at least in UK, Sweden and New Jersey. In all of these, the regulation was interpreted in different ways, leading to all operators having varying rules that are non-negotiable. It will be a wild beginning, and its best to prepare for a lot of customization if you want to keep all key operators in.

 

[nibnab]

Its the same thing every time - happened at least in UK, Sweden and New Jersey. In all of these, the regulation was interpreted in different ways, leading to all operators having varying rules that are non-negotiable. It will be a wild beginning, and its best to prepare for a lot of customization if you want to keep all key operators in.

This whole regulation will have the same end result as Sweden did. Operators will struggle, leave the market and the non-EU brands will be the biggest winners.

 

[preditor]

This whole regulation will have the same end result as Sweden did.

I would not wonder if Sweden also soon says "You can not mention casino, jackpots etc".
My Swedish sites mentions jackpots and pay n play instead of thouse 100kr bonuses - would be terrible to update if we would get that in Sweden also

 

[Lucy CBC]

Indeed, we've started receiving several similar emails as well, but instead of providing us with any kind of in depth details, most simply say they will have German players restricted until further notice..that's probably to avoid the big hassle and confusing compliance terms.
From what I read here, it's quite hardcore and perhaps not worth it in many cases...yes, it seems Germany follows Sweden and UK...will do some more research on the topic.

 

[Tupee]

• "Remove all promotional material/banners for casino products such as landing pages and banners that you have acquired through our affiliate system from all German facing websites"
  
  But how do you advertise casinos then? If no promo material? Only by text?

 

[danniee]

This has been on the horizon for a loooong time, so it shouldn't really come as a surprise. As an affiliate, you need to keep one ear constantly to the ground. Shifts and changes are always going to happen and soon all of Europe is regulated.

The word on the street is that Germany as a market is f***ed. 1000€ max deposit per month for players, max 1€ stake, 5 second spin delay. Ugh.

Casinos can't even have the word casino in their name/domain so places like Trada Casino and Genesis Casino etc need to get new domains and redirect players there.

But yeah, GiG for example pulled out all their brands + a few others.

 

[TheGooner]

This is our summary so far:

German Compliance Requirements & Toleration Criteria

Thanks for the detailed summary Melcb - greatly appreciated.!

 

[nibnab]

This has been on the horizon for a loooong time, so it shouldn't really come as a surprise. As an affiliate, you need to keep one ear constantly to the ground. Shifts and changes are always going to happen and soon all of Europe is regulated.

not really a surprise, it has been on the horizon for a long time. However, the timeline for the whole thing is just mind-blowing:

- Sept 10 - states agree to a "toleration" policy to let operators continue between now and July
- Sept 30 - tolerance policy is published
- Oct 1 - Operators: *sound of panic*
- Oct 15 - Operators must adhere to most rules in the policy
(source twitter:@ pokerprojones)

The implementation of the "panic button" is something I just don't see happening very quickly.
Also the rule of not using the word "Casino/Kasino" is just a signal that Germany is trying to make this as difficult as possible for operators.

 

[Skyla Burrell]

I think we need a panic button too

 

[Lucy CBC]

I think we need a panic button too

totally!

 

[AussieDave]

I pity those affiliates who have literally 100's if not 1000's of pages. The thought of having to re-edit all pages which 'could' be accessed by the German market, is mind boggling. That, and the woefully short notice.

Have to wonder if the short notice is a genuine oversight, or a staged excuse to close accounts if not done within the time-frame.

 

[danniee]

I remember a couple of years ago playing slots in a German spielhalle and it took ages to spin the reels. Was some kind of countdown between each spin so you had to wait a ridiculously long time. Finally gave up and couldnt be arsed. I get it, gambling can be harmful but not all gamblers have a gambling problem. It's retarded to ruin the fun for everyone.

 

[Biti]

Just like everywhere regulation means for most affiliates a lot of more work to comply, a lot of bothering affiliate programs who interpretate the rules all different, higher costs and less earnings.

 

[NDG]

I already received an e-mail from an affiliate program telling me to quit referring to their
casino as a casino. I can call it anything else, but I can't call it what it actually is.

The German regulators are going to allow their citizens to play slots (that have the worst odds),
but they won't be able to play blackjack or any other table game that has much better player odds.

I'm sure the licensed casinos in Curacao are excited about all of these regulatory changes,
because they can offer more games, bigger bonuses, etc.. to players from these countries.