Germany's publisher landscape under the GlüStV: why so many German sites refuse casino content, and what that leaves

Buyers who move from English-language iGaming campaigns into Germany meet the same answer from publisher after publisher: sports betting content is fine, casino content is not. The refusal rate is high enough that German-language inventory for casino brands can look as if it barely exists. It is not prejudice on the publishers' part. It follows from the way the Interstate Treaty on Gambling 2021 (Glücksspielstaatsvertrag, GlüStV 2021) divides the market, and from a criminal provision that makes the publisher, not only the operator, answerable for advertising an unlicensed product. This article sets out the legal position as of 2 November 2026, with the primary sources, and what it leaves for German-language placements.

Two products, two permission regimes

The GlüStV 2021, in force since 1 July 2021 and supervised since 2023 by the Gemeinsame Glücksspielbehörde der Länder (GGL), treats the products that English speakers lump together as "online casino" as three different things, as the GGL's explanation of gambling types sets out.

Sports betting is licensed nationwide by the GGL. Virtual slot machines (virtuelle Automatenspiele) and online poker are also licensed nationwide by the GGL. Online casino games in the legal sense, meaning virtual versions of banker games such as roulette and blackjack, are not. Under section 22c of the treaty, each Land decides for its own territory whether to permit them at all, either through a state-controlled company or through a limited number of concessions, capped at the number of land-based casino concessions in that Land. According to law-firm analysis, only North Rhine-Westphalia and Schleswig-Holstein have pursued the concession route, several Länder have chosen a state monopoly, and others have done nothing.

The result is that a product marketed across Europe as an "online casino" is, in most of Germany, either an unlicensed offer or a licensed virtual slots offer that is legally forbidden from calling itself a casino. The GGL's FAQ on legal online casinos states that licensed virtual slot operators may not use the terms "Casino" or "Casinospiele", which are reserved for the Länder-run casinos, and that doing so is an administrative offence. An article that promotes a brand as an online casino is therefore non-compliant on its face, whoever the operator is.

The GGL's whitelist is the only reliable test of what may be advertised. In its five-year review of September 2026 the authority put the list at 129 licensed operators and brokers with 229 permitted websites; its 2024 activity report counted 40 licensees for virtual slot machines and five for online poker at the end of that year. Any brand not on the list is, for a German publisher, an illegal offer.

Why the publisher carries the risk

Three provisions explain the blanket refusals.

First, section 284(4) of the Criminal Code makes advertising an unlicensed public game of chance a criminal offence, punishable by up to one year's imprisonment or a fine. The offence attaches to whoever advertises, which includes the publisher that carries the content. Since most "online casino" brands are unlicensed in Germany, and since a publisher cannot easily verify which are not, the rational editorial policy is to refuse the category.

Second, section 5 of the treaty bans advertising for virtual slot machines, online poker and online casino games on broadcast media and the internet between 6:00 and 21:00 (section 5(3)). A sponsored article is online around the clock, so even content for a licensed virtual slots brand sits uneasily with the daypart rule, and publishers are not paid enough to litigate the point. Sports betting advertising is not subject to this window; its main restriction (section 5(4)) concerns advertising immediately before and during live broadcasts.

Third, the GGL's licence conditions for advertising, which the Higher Administrative Court of Saxony-Anhalt upheld, permit affiliate marketing only where the affiliate site links solely to licensed operators and require advertising on such sites to be recognisable as advertising. The treaty also prohibits variable, turnover- or deposit-based remuneration for advertising the products covered by the national self-exclusion system (section 5(6)), which removes the revenue-share model that funds much casino affiliate content elsewhere. The GGL has acted against advertising for illegal gambling by streamers and websites, and reports having examined around 6,300 websites for illegal offers or advertising by the end of 2025.

A German news or sports publisher weighing a casino placement therefore sees a product that is probably unlicensed, a term it may not use, an advertising window it cannot honour and a personal criminal exposure. Refusal is the predictable outcome.

Why sports betting is different

Sports betting operators hold nationwide GGL licences, appear on the whitelist, may describe their product plainly, and face no daypart ban on internet advertising. The most recent addition shown on the GGL's whitelist in October 2026 was a sports betting licence. German publishers can check a brand in minutes and carry its content with a clear conscience, which is why sports-focused sites, regional news portals and general-interest magazines routinely accept betting previews, odds comparisons and bookmaker reviews while refusing anything with a slot or a roulette wheel in it.

The refusal pattern buyers observe is thus a legal map, not a cultural one. The same editor who declines casino content will take sports betting content from a licensed operator, provided it respects the advertising rules on minors and on live broadcasts.

What that leaves

For a buyer with German-language campaigns, the usable inventory divides into four groups.

1. Sports betting content for whitelisted operators. The largest and most reliable segment. Publisher acceptance is broad, and the content rules are manageable.
2. Virtual slots content for whitelisted brands, written to the rules. Possible on specialist and affiliate sites that have accepted the GGL conditions: no "Casino" terminology, fixed rather than revenue-share remuneration, clear advertising labels and links only to licensed offers. General-interest publishers rarely take it.
3. Informational content with no promotional element. Articles about regulation, player protection or the licensing system itself are not advertising and are accepted widely. They build authority without naming an unlicensed brand.
4. Austria and Switzerland. German-language, but separate jurisdictions with their own regimes, and not a substitute for German inventory when the campaign targets Germany.

Two things may change the map. The Länder have signed an amending treaty whose ratification by state parliaments was still in progress in 2026, and the formal evaluation of the GlüStV 2021 is due by the end of 2026, with advertising among the subjects the GGL's leadership has said should be examined. Neither has altered the rules above as of this article's date. A GGL-commissioned study found that licensed offers account for about three quarters of German online gambling, so the regulated market, not the grey one, is where German publishers will remain.

Applying this when you order

Classify German publishers in three states, not two: accepts sports betting only, accepts virtual slots content under the GGL conditions, or accepts no gambling content. Brief casino campaigns in Germany as virtual slots campaigns and strip the word "Casino" from the copy. Check every advertised brand against the GGL whitelist before an order is placed, because the publisher will. In the RBN Media Portal every publisher carries a gambling policy classification that distinguishes sports betting only from full gambling acceptance, so German-language sites can be filtered to the right state before the brief is written.