Slot association sets out wish list for German re-regulation

21 October 2019

The Deutsche Automatenwirtschaft (DAW), the umbrella organisation for Germany’s gaming machine associations, has highlighted a number of key issues that must be addressed as lawmakers prepare to begin discussions over the re-regulation of the country’s gambling market.

The DAW explained that current regulations for commercial gambling, based on quantative rather than qualitative criteria, undermine the objectives of the State Treaty on Gambling, in particular when it comes to channeling players towards the legal market.

It said establishments should be permitted to offer multiple game verticals, and that updated regulations should maintain the state lottery monopoly on draw-based games.

New regulations, which are to be debated at the Minister-President Conference from Wednesday 23 October, must ensure legal providers can offer a competitive and ecnomically viable alternative to unlicensed operators, the DAW said.

The Conference will see lawmakers debate changes to German gambling laws, which would come into force from 30 June, 2021. The third amended State Treaty, which was ratified earlier this year, will see sports betting licences issued early in 2020, but only as a placeholder until a more comprehensive overhaul can be agreed upon.

"The amendment of the State Treaty on Gambling is a great opportunity to counteract the undesirable developments - above all the rapid growth of the black market - with a holistic approach,” DAW chief executive Georg Stecker explained. “Only a coherent regulation of all forms of gaming, including the use of commercial slot machines based solely on quality standards, and a strengthening of legal providers can curb the black market and effectively protect consumers.”

He warned that the legalisation of online gaming, which could be approved at the meeting, must be accompanied by an overhaul of land-based gaming machine regulations. Allowing products such as slots to be widely available online, while maintaining strict laws such as restrictions on the distance between land-based gaming halls, would disturb the equilibrium of the market, he added.

As such, the DAW, which incorporates the Verband der Deutschen Automatenindustrie (VDAI), the Deutsche Automaten-Großhandels-Verband (DAGV), Bundesverband Automatenunternehmer (BA) and FORUM der Automatenunternehmer (FORUM), has set out five areas it wants addressed in the revised State Treaty.

It calls on state lawmakers to introduce uniform standards for responsible gaming training and player protection measures across all sectors. These controls, it says, must be constantly developed and regularly evaluated by professionals to ensure they are fit for purpose.

A nationwide biometric system that would ensure voluntary restrictions on players’ gambling should also be rolled out. The DAW believes this would aid the State Treaty’s goal of protecting players, by preventing them from moving to gamble via new channels as soon as they block themselves from others.

It also believes a certification system for all gaming halls and outlets offering slot machines should be implemented, to help consumers distinguish legal from illegal offerings. This would also simplify enforcement of regulations, it added.

In addition, the association argues in favour of a qualification system for gaming machine professionals. This, it says, should include a tailored teaching programme and examinations.

Finally, the DAW argues in favour of regulations governing the exterior design of gaming establishments. It says these should ensure there are no inducements to gamble for minors and vulnerable people, while allowing the operator to inform and educate players about the range of games on offer.