What happens in the event of payment blocking by the GGL?

The Joint Gambling Authority of the Federal States (GGL) instructs payment service providers to stop transactions to unlicensed gambling providers. Your private bank account remains fully functional. Only the individual transfer to the illegal operator is rejected. This measure enforces the State Treaty on Gambling 2021 and protects players from unregulated offers without disrupting general payment transactions.

What is payment blocking and how does it work technically?

The GGL uses payment blocking as a main instrument to enforce the State Treaty on Gambling 2021 (GlüStV 2021). The authority prohibits payment service providers from processing transactions to illegal gambling providers. This so-called financial blocking does not aim to block private accounts. It specifically stops the flow of money to unlicensed platforms by instructing banks and payment providers to reject specific payments.

The mechanism: How banks detect illegal transactions

The technical implementation of payment blocking by the GGL is based on close cooperation with payment service providers. The authority transmits lists of unauthorized providers. The financial institutions then cross-reference their transaction data. For identification, banks use specific characteristics such as Merchant Category Codes (MCC), which identify gambling transactions, as well as IP address checks and domain blacklists.

Critics such as the Independent State Centre for Data Protection Schleswig-Holstein (ULD) point out that a seamless distinction between legal and illegal gambling is difficult with the available data. Financial blocking often requires a secondary use of customer data, which can be problematic under data protection law. Nevertheless, the GGL rates this method as effective because it increases the effort for illegal providers and makes Germany less attractive as a market.

Overview of affected payment methods

Blocking affects almost all common digital payment methods. Traditional services like Giropay and Paysafecard are just as restricted as modern open banking solutions. Trustly, a Swedish payment service provider for direct transfers, must also stop transactions to listed illegal providers. Similarly, Klarna (formerly Sofortüberweisung) is integrated into the GGL's blocklists. Installment payments or instant transactions to unauthorized casinos fail as a result.

Mobile wallets such as Apple/Google Pay are not immune either. Since these services often only act as a technical bridge for stored credit or debit cards, payment blocking also applies here as soon as the recipient is identified as illegal. The GGL is working to close these gaps, although some providers try to bypass the blocks via complex chains of payment services.

Account suspension myth: What happens to my money?

Many players falsely fear that the GGL will block private bank accounts. This is incorrect. In the case of payment blocking, only the individual transaction to the illegal provider is rejected. The player's private checking account remains fully operational. The money is not confiscated, but remains in the account or is transferred back in the case of a transaction that has already been initiated.

No negative Schufa entries are created by this specific rejection. It is an official prohibition of the business relationship with the provider, not a credit check of the customer. The measure serves to combat illegal gambling within the framework of the GlüStV 2021, without restricting the general financial freedom of citizens. However, players should note that repeated attempts to bypass blocks can lead to further administrative measures.

Legal basis: The role of the GGL and the GlüStV 2021

Regarding the question of what happens in the event of payment blocking by the GGL, the authority relies on the State Treaty on Gambling 2021 to stop payment flows. The GGL issues a prohibition order against payment service providers. Failure to comply can result in high coercive fines. This measure primarily aims to interrupt the financial connection to illegal providers. The Higher Administrative Court (OVG) of Saxony-Anhalt has confirmed the legality of these interventions.

GlüStV 2021 as a basis for financial blocking

The State Treaty on Gambling 2021 (GlüStV 2021) forms the central legal foundation for combating unauthorized gambling in Germany. Specifically, Section 4 Paragraph 1 Sentence 2 of the GlüStV authorizes the supervisory authorities to prohibit not only the organizing of, but also participation in payments in connection with unauthorized gambling. This standard turns payment service providers into so-called "interferers" (Handlungsstörer) who are legally obligated to block transactions. In addition, Section 9 Paragraph 1 Sentence 3 No. 5 of the GlüStV 2021 allows measures against service providers if direct action against the organizer is not promising.

The GGL (Joint Gambling Authority of the Federal States) uses this authority to enforce so-called financial blocking measures. In contrast to IP blocking, which affects Internet Service Providers and cuts off technical access, payment blocking targets the economic basis of illegal providers directly. Nadja Wierzejewski, the President of the GGL, therefore describes payment blocking as the "sharpest sword" in the authority's arsenal, as it directly reduces the attractiveness of the market for illegal operators. By stopping the payment channels, the business model of these providers is sustainably disrupted, without a technical block of the domain necessarily being required.

Judicial confirmation by the OVG and Federal Administrative Court

The legal viability of these measures has already been reviewed in court several times. The Higher Administrative Court (OVG) of Saxony-Anhalt confirmed the legality of payment blocking orders in a landmark decision. The court stated that the gambling authority makes a discretionary decision in individual cases that complies with the principle of proportionality, especially given the high potential for addiction and the risk of money laundering. Although a payment service provider cannot verify the origin of every payment with absolute certainty, it is obliged to demand proof of technical precautions from the providers.

In parallel, the Federal Administrative Court is dealing with the controversial practice of IP blocking, in which Internet Service Providers are requested to block IP addresses. While payment blocking is largely legally secure, the legality of IP blocking is still pending final clarification. This judicial differentiation shows that the GGL adapts its strategies to the respective legal situation: where IP blocking is legally shaky, the authority increasingly relies on the financial levers of payment blocking, which were recognized as legal by the Higher Administrative Court of Saxony-Anhalt.

Enforcement means: From notice to coercive fine

Enforcement of GGL orders follows a clear escalation path. First, a formal prohibition order is issued to the affected payment service provider or bank. This order requests the recipient to terminate the business relationship with the illegal gambling provider or to prevent specific transactions. Since many of these providers are located abroad, direct enforcement against the operator is difficult. Therefore, the payment channel regulated in Germany is used as a lever.

If the payment service provider does not comply with this prohibition order, sensitive sanctions threaten. The GGL can impose a coercive fine based on the economic capacity of the company. This high financial risk explains the high level of cooperation from banks and payment providers. Nadja Wierzejewski emphasizes that, despite limited capacities, the authority prioritizes and focuses on the most relevant illegal offers. Through the combination of the legal basis in the GlüStV 2021 and the threat of massive coercive fines, the GGL creates an effective filter that pushes illegal gambling offers out of the German payment area.

Payment blocking vs. IP blocking: Differences and synergies

Regarding the question of what happens in the event of payment blocking by the GGL, the authority intervenes directly in payment flows by instructing payment service providers to stop transactions to illegal providers. In contrast, IP blocking aims to interrupt technical access to the website via Internet Service Providers. While payment blocking is considered a highly effective instrument that dries up the financial basis of illegal offers, the implementation of IP blocking is legally controversial and technically easier to bypass.

IP blocking: When access to the website is blocked

IP blocking, also known as net blocking, is an enforcement tool used by the GGL when unauthorized gambling providers do not cease operations despite a prohibition order. In doing so, the authority requests Internet Service Providers to block access to certain IP addresses or domains. However, this approach hits technical and legal limits: since IP blocking filters data traffic at the network level, users can often bypass these blocks using VPNs or proxy servers.

From a regulatory perspective, enforcing IP blocking is significantly more difficult than enforcing payment blocking. The Higher Administrative Court of Saxony-Anhalt and other courts have critically reviewed the legality of such blanket access blocks, as they can be classified as disproportionate. Nadja Wierzejewski of the GGL therefore describes payment blocking as the "sharpest sword" because it cuts off the direct financial supply to illegal providers, while IP blocking merely represents a hurdle that technically savvy players can easily overcome. The GGL must also weigh up in the case of IP blocking whether the effort for the Internet Service Providers is proportionate to the protection goal, which leads to delayed implementations.

The risk of overblocking and errors

A key problem in enforcing payment blocking is so-called overblocking. Since payment service providers often cannot distinguish between legal and illegal gambling transactions with absolute certainty, there is a risk that permissible payments or transactions to licensed providers abroad will also be blocked. This happens when the technical characteristics of a transaction, such as the Merchant Category Code, are not precise enough to fully represent the context.

Overblocking presents payment service providers with a dilemma: they must either run the risk of violating GGL orders or set their filters so strictly that they potentially lose legal customers. Critics argue that the available data is often insufficient to make an error-free distinction, which can lead to false positives. For players, this means that a rejected transaction does not automatically indicate a blocked account, but is often due to a too broad interpretation of the blocklists by the financial service provider.

Evasion techniques: Cloaking and its limits

Illegal providers are increasingly trying to bypass blocks using technical tricks such as cloaking. With cloaking, the user or the supervisory authority is shown different website content than the actual, illegal gambling operation. This method is intended to make it more difficult to uncover the identity of the operators behind the illegal offers, thereby delaying the enforcement of payment blocking and IP blocking.

The GGL is responding to cloaking and other evasion tactics by expanding its capacity to identify those responsible, even if this is costly due to missing imprint details. Despite these technical games, payment blocking remains effective because it attacks the financial transaction level independently of the website interface displayed. As long as the payment flows are identifiable, the GGL can request the payment service providers to stop them, which reduces the incentive for cloaking in the long term, as the monetary basis is missing.

Data protection concerns and criticism of financial blocking

With payment blocking by the GGL, not only technical hurdles but also fundamental legal issues are in play. Critics, including the ULD, complain that financial blocking severely encroaches on payment freedom and data protection. The central concern is overblocking, where payment service providers wrongly stop legal transactions, as well as the lack of transparency for affected consumers.

Statement of the ULD on interventions in payment freedom

The Independent State Centre for Data Protection Schleswig-Holstein (ULD) has expressed significant data protection concerns in its assessment of the financial blocking regulations. The core of the criticism is the required data processing: in order to filter illegal gambling transactions, payment service providers must evaluate sensitive information such as the recipient's name, account details and specific merchant codes. The ULD questions whether this secondary use of stored data is compatible with data protection law. Furthermore, it is argued that the available data is often insufficient to distinguish clearly between legal and illegal gambling, which leads to legal grey areas. This uncertainty burdens the GGL and the financial institutions involved, as the distinction in individual cases remains complex.

Proportionality of the measures

The proportionality of payment blocking has been intensively reviewed by the courts. The Higher Administrative Court of Saxony-Anhalt confirmed the legality of the measures, although so-called overblocking cannot be completely ruled out. This means that payments to legal providers abroad could also be blocked. Nevertheless, the court saw the interventions as proportionate, since the GGL makes a discretionary decision within the framework of combating unauthorized gambling. From a regulatory perspective, protecting players from addiction and manipulation carries more weight than the potential restriction of payment freedom for individual transactions. The GGL argues that although digital freedom rights are of high standing, the societal mandate for prevention takes precedence.

Transparency for the consumer

A common point of criticism is the lack of information for users. When a transaction is rejected, players often only receive a cryptic error message without it being clear whether payment blocking by the GGL or an internal bank security check is the reason. This lack of transparency makes it difficult for consumers to exercise their rights or challenge false positives. Although the GGL is working on better education, in everyday life the distinction between a technical fault and an official block often remains opaque for the individual payment service provider customer. However, transparency is essential for responsible gambling in order to prevent loss of control.

Player and consumer protection: OASIS, limits and BzgA

Besides payment blocking, the German gambling market is characterized by strict consumer protection measures, which must be implemented by licensed offers. These instruments serve to prevent gambling addiction and protect players from financial harm.

The OASIS locking system

The online exclusion system OASIS (State Authority Information System for Player Exclusion) is a central element of the GlüStV 2021. Licensed providers are obliged to check every player in OASIS before registration. If a player is banned there, they are not allowed to play at any licensed provider in Germany. This effectively prevents players from moving from one provider to another to bypass bans. Payment blocking complements this system by stopping the flow of money to unlicensed providers that are not connected to OASIS.

Deposit and bet limits

To limit financial risks, the GlüStV 2021 prescribes strict limits. Players may deposit a maximum of 1,000 euros per month with licensed providers. In addition, a bet limit of 1 euro per spin applies to online slots. These limits are implemented and monitored technically by the providers. Anyone who tries to bypass these limits by using multiple accounts or unlicensed platforms risks not only losing their money due to a lack of legal protection, but also a ban in the OASIS system.

Role of the Federal Centre for Health Education (BzgA)

The BzgA supports prevention work through information campaigns and counseling offers. Players who feel they are losing control of their gaming behavior can seek advice anonymously and free of charge. The GGL always refers to these help offers in its communications to emphasize the preventive character of the State Treaty on Gambling. Payment blocking is therefore only one component of a comprehensive protection concept that also includes psychosocial support and technical limits.

Impact on players: Alternative providers and crypto casinos

When the GGL stops transactions to illegal platforms, many players wonder whether cryptocurrencies represent a loophole in the GGL's payment blocking. While the GlüStV 2021 effectively blocks classic payment methods, providers are shifting to decentralized networks, which presents regulatory authorities with new technical challenges and increases the risk for players.

Why crypto casinos are harder to block

Do cryptocurrencies like Bitcoin offer a way out of payment blocking? Yes, technically speaking, crypto casinos bypass traditional financial controls because transactions do not run through centralized payment service providers that the GGL can oblige to cooperate. Instead of bank transfers, these platforms use blockchain networks. BTC (Bitcoin) and ETH (Ethereum) enable pseudonymous deposits that are hard for banks to trace. Stablecoins like USDT (Tether) are also frequently used because they are price-stable while still offering the advantages of the crypto infrastructure.

The GGL has identified this evasive movement. Nadja Wierzejewski, Head of Department 3, describes the fight against crypto casinos as a major project for the coming years. Since the GlüStV 2021 also classifies playing with cryptocurrencies at unlicensed providers as illegal, the authority is working on new methods to close this gap. The advantage for players is the apparent anonymity. The disadvantage is the complete elimination of the consumer protection that licensed providers must offer.

Risks of playing without a German license

What are the risks for players who bypass blocking measures? Anyone who switches to crypto casinos leaves the protective space of the GlüStV 2021. In contrast to licensed providers, platforms that only accept BTC, ETH or USDT often have no connection to the OASIS ban system and no guaranteed payout. The GGL explicitly warns of the risks of illegal gambling, as German courts cannot be called upon in the event of a dispute.

In addition, the use of cryptocurrencies is volatile (except for stablecoins like USDT) and technically complex. Mistakes when entering the wallet address lead to the irreversible loss of funds. The GGL's payment blocking serves not only to stop illegal offers, but also to protect players from such unsecured environments. Anyone who bypasses the blocks does so at their own risk and waives the safety standards anchored in the GlüStV 2021.

The future of blocking: Further tightening?

How does Nadja Wierzejewski see the further development of blocking instruments? The Head of Department 3 of the GGL emphasizes that payment blocking is currently the "sharpest sword" in the fight against illegal gambling. However, the authority is not resting on this success. For the future, the GGL plans to specifically close the gaps in crypto casinos.

Nadja Wierzejewski announces that the fight against crypto offers and so-called cloaking (masking the true identity of a website) will be a priority. It can be assumed that the GGL, in close coordination with international partners and technology providers, will find new ways to better track transactions in BTC, ETH and USDT or to block access to these crypto casinos directly. The GlüStV 2021 provides the legal framework for this, which is dynamically adapted through administrative measures by the GGL. Players should be prepared for the fact that bypassing payment blocking via cryptocurrencies will become increasingly difficult and risky.

About this article - Editorial & Responsibility

✍️ Author: Sarah Weber – Casino Tester & Bonus Analyst

⚖️ Expertly reviewed by: Dr. Markus Hoffmann – Senior iGaming Compliance Analyst

📅 Last update: 2026-06-26

This article on "what happens in the event of payment blocking by the GGL" was written by Sarah Weber and expertly reviewed by Dr. Markus Hoffmann. Both regularly update the content regarding regulatory changes, license availability, and bonus conditions. All statements regarding licenses, authorities, and legal frameworks refer to publicly accessible sources (GGL (Joint Gambling Authority of the Federal States), State Treaty on Gambling 2021 (GlüStV 2021)).

About the author

8+ years of casino reviews, 200+ personally tested platforms in the EU and internationally. Former member of the eCOGRA Player Advocacy Program (2018-2022). Specialization: wagering requirements, payout workflows, customer support assessment.

About the reviewer

12+ years in the iGaming industry, including 5 years as a compliance consultant for licensed operators under the State Treaty on Gambling 2021. PhD in Business Mathematics. Main research areas: bonus mathematics, wager analysis, player protection systems (OASIS).

Responsible Gambling

Gambling can be addictive. If you feel you are losing control of your gaming behavior, please contact BzgA gambling addiction help, Check-dein-Spiel.de or use the central exclusion system (OASIS (central player exclusion system)). Set personal deposit and loss limits before playing with real money. Breaks and cooldown functions from providers are not a sign of weakness - they are a tool for sustainable fun in the game.

Legal Notice

The information in this article is for editorial and comparison purposes only. It does not constitute legal advice. The legal assessment of online gambling without a German license is a grey area and is subject to ongoing adjustments by the GGL (Joint Gambling Authority of the Federal States). Players are responsible for compliance with local regulations.