Virtual Slot Machine Games

Virtual Slot Machine Games only with Gambling License from GGL

Virtual slot machines are a form of gambling that requires a gambling license under the German Gambling Regulation (GlüStV). It exists in the case of replicas of terrestrial slot machine games offered on the internet. These include, in particular, the reel games also known as one-armed bandits and other electronically or mechanically operated slot machines in which, once the game has started, the chance of winning depends entirely or predominantly on chance. In order to be allowed to organize a virtual slot machine game on the internet, the provider must first obtain a gambling license from the Joint Gambling Authority of the Federal States (GGL) as an organizer. Additionaly to the operator license, however, the operator of a virtual slot machine game must also have each of its individual virtual slot machine games licensed separately by the GGL. In this respect, the GGL checks each individual virtual slot machine game planned by the organizer prior to its activation on the internet and ensures that the requirements of the German Gambling Regulation are fully complied with. These are comprehensive, which is why the support of a specialized lawyer or law firm can be useful.

Requirements for Virtual Slot Machine Games in Accordance with the German Gambling Regulation

Only virtual slot machine games offered on the internet are eligible for licensing under the German Gambling Regulation. Terrestrially operated slot machine games via physical slot machines, on the other hand, are subject to approval under the German Trade Regulation Act (Gewerbeordnung). According to the regulations of the German Gambling Regulation, the GGL can only issue a gambling license for the organization of virtual slot machine games if, in particular, it is ensured that the contracting party of the players is in fact always the organizer itself and not, for example, a gaming broker or other platform operator. In order to protect players, virtual slot machine games may not last for less than five seconds on average. In addition, the organizer of the virtual slot machine game must ensure that a single game only starts after the player has declared the start of the game and that further single games of the same player can only be started after the previous game has ended by the player declaring the start of the game again. It must not be possible to start several single games by only one declaration of the player. If a physical device is simulated by a virtual slot machine game, the organizer must ensure that the simulation corresponds to the expected behavior of the physical device in order to avoid misleading the players. Furthermore, virtual slot machine games are only licensable if the organizer provides the players with the essential information on the game, such as the rules of the game, the probabilities of winning and the average payout per euro wagered, in a manner that can be easily viewed.

Gambling License for Virtual Slot Machine Games on Basis of Two-Stage Procedure of GGL

In order to obtain an organizer’s license under the German Gambling Regulation for the organization of virtual slot machine games, it is necessary to apply for a gambling license from the GGL. In addition, organizers must also have each planned individual virtual slot machine game checked and permitted by the GGL. The individual game review is carried out according to a separate procedure, which the GGL has formalized. Organizers of virtual games of chance must use a CSV file provided by GGL for the individual game review, which must be completed by the applicant strictly in accordance with the authority’s specifications. In the second step, the virtual slot machine game organizer must provide GGL with free access to the virtual slot machine game, through which the authority can check the single game in its full functionality. Finally, the organizer must specify the order in which the GGL should review the individual games. This procedure allows the authority to permit some prioritized individual games at the same time as granting an organizer a gambling license, so that the organizer can already start offering the games immediately after receiving the gambling license. If the operator changes individual virtual machine games after the license has been issued, these must be reviewed again by the GGL before they may be operated in the new version.

The competent lawyer for advice regarding a gambling license for virtual slot machine games in accordance to the German Gambling Regulation 2021 in our law firm is Attorney Lutz Auffenberg, LL.M (London).