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He emphasised the new system would make burdens less demanding than before, but the new ‘exit plan’ requirement and sharper duty‑of‑care definitions do bring some added complexity.
The KSA said that applicants were previously required to detail corrective actions taken to address previous breaches and outline measures to prevent future violations.
All submissions must also now include an exit plan – a new obligation that applies across the board. This requirement, intended to ensure orderly market withdrawal, marked a move toward embedding long-term risk management into the licensing process.
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Meanwhile the government has been approaching the issue via a new bill. Sports minister Sadok Mourali said in November 2024 that a gambling and sports betting bill had been circulated for consultation. Twenty-six public institutions received that consultation, including the central bank, Competition Council and financial intelligence authority.
A year later he said the draft had been completely revised to bring it into line with international standards on sports betting manipulation and money laundering.
The text has not been published. It is not known whether it would allow private operators to be licensed or simply modernise Promosport’s monopoly. Mourali told a parliamentary committee in November 2025 that a new law would digitise sports betting.
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The decision is not yet legally binding, with a further opportunity to appeal the denial of ‘leave to appeal’ open to the applicants. This will be reviewed by the Federal Administrative Court of Leipzig.
In his original complaint, Braun also cited a study that found that nearly half of respondents were thinking of using illegal gambling services due to legal restrictions.
In recent weeks, German authorities conducted a crackdown on an alleged illegal online gambling operation suspected of facilitating wagers totalling approximately €5.86 billion over a 30-month period.
