A €5 Maximum Stake Does Not Mean Five Times the Losses

Andreas: Parts of it absolutely are. Other parts, I find problematic.

For example, I think the call for greater transparency is entirely legitimate. If a regulator changes a significant product rule, it should explain clearly why it is doing so and on what evidence the decision is based. I also support the call for a scientific evaluation of the effects.

But there is one crucial point where I have a problem with the letter: it partly conflates what is theoretically possible with what is actually happening.

And that is exactly why we should now talk about data.

Andreas: The open letter uses, among other things, the example of a player continuously staking €5 per spin. Assuming a return-to-player rate of 87%, the authors calculate potential statistical losses of up to €468 per hour. Under this model, the monthly deposit limit of €1,000 could effectively be exhausted after just over two hours of play.

The math is understandable.

But it does not answer the crucial empirical question: Do people actually play like that?

A speed limit of 250 kilometers per hour would not mean that the average speed on a highway suddenly becomes 250 kilometers per hour.

Andreas: Exactly. That is the intuitive conclusion. But a higher maximum is not the same thing as a higher average.

The first industry figures we are seeing paint a much more nuanced picture.

At Hölle Games, for example, around 95% of all spins in July remained at €1 or below. Around 4.3% were between €1 and €3, and only 0.6% were between €3 and €5.

There is another interesting figure: around 8% of active players tried a stake above the old limit at least once in July. Yet only around 5% of all spins were actually above that old limit.

That distinction matters.

Andreas: Because it suggests that many players try the new option without permanently switching to higher stakes.

To me, that is the most interesting observation so far.

Regulation theoretically allows a jump from €1 to as much as €5. Actual behavior, however, shows nothing resembling that kind of jump. Players experiment with higher stakes, but many of their spins apparently remain at, or return to, lower stake levels.

You could put it this way:

The regulatory ceiling increased fivefold. Player behavior did not.

Andreas: Yes. And probably even more clearly.

The initial industry data we have suggests average stakes before the change were around €0.43. In July, we are seeing figures of roughly €0.45 to €0.46, depending on the provider, portfolio and dataset.

So, at the moment, we are talking about an increase somewhere in the region of 5–7%.

Not 100%.

Not 400%.

And certainly not a fivefold increase.

That does not mean a 5–7% increase is irrelevant. But for a serious assessment, there is a fundamental difference between a roughly 7% increase in the average stake and a 400% increase in the theoretical maximum stake.

Andreas: I would phrase it differently. It identifies a legitimate risk, but parts of the argument rely on worst-case framing.

The letter explicitly argues that virtual slots have a high addictive potential. It points out that virtual slots accounted for 22.6% of the primary forms of gambling reported among people attending counseling services, and it cites data suggesting that, among people who gamble, those participating in virtual slots show a particularly high prevalence of gambling-related disorders.

Those are serious points and they deserve to be taken seriously.

But they do not automatically demonstrate that increasing the maximum possible stake from €1 to €5 will multiply actual player losses fivefold.

That link has to be demonstrated empirically.

And that is exactly what makes the coming months so important.

Andreas: I am supportive of the data.

If, six months from now, the data shows that average stakes have increased dramatically, that high-risk players are suffering substantially greater losses, and that relevant player-protection indicators have deteriorated, then we need to talk about that, and potentially adjust the regulation.

But if we find that the overwhelming majority of spins continue to take place at €1 or below and the average stake has moved only moderately, then we have to accept that evidence too.

Regulation should be evidence-based.

That principle has to work in both directions.

Andreas: And I think that is one of the stronger arguments in the letter.

The signatories criticize the fact that the change was made while the evaluation was still ongoing and argue that there was insufficient independent scientific evidence supporting both the timing and the specific nature of the adjustment. Among other things, they call for a transparent public justification, independent scientific monitoring and greater involvement of experts and stakeholders.

I can agree with a great deal of that.

But if we demand more evidence, we have to be consistent. We cannot simultaneously take a theoretical loss calculation and treat it as evidence of actual player behavior.

Evidence-based regulation cannot be a one-way street.

Andreas: Absolutely. And I am not saying that.

July is one data point. It is not a longitudinal scientific study.

There is seasonality. There are differences between operators and game providers. Promotions and free spins can influence the average spin value. Sports betting and casino products have cross-selling effects. And behavioral changes may take time to emerge.

So it would be irresponsible to say: “Look, everything is completely harmless.”

But the opposite statement would be equally irresponsible: “The maximum stake has increased fivefold, therefore losses will increase dramatically.”

We simply do not know that yet.

What we do know is that the dramatic jump implied by the headline numbers is not visible in the first available behavioral data.

Andreas: It is interesting because, back then, we did not have a comparable €1 stake restriction.

According to industry data, the average spin value for German players before the introduction of the German license was approximately €0.70. After regulation was introduced, it gradually declined from around €0.51 to approximately €0.43 over several years.

Again, that demonstrates an important point: players do not automatically stake the regulatory maximum.

Average stakes emerge from a complex mix of decisions: player type, game mechanics, promotions, free spins, bankroll, previous wins and many other factors.

A maximum is a ceiling, not a prediction of behavior.

Andreas: That is actually the much more interesting question.

German gambling regulation does not only aim to restrict gambling intensity. It also aims to channel players into the regulated market.

And for that to work, the regulated market has to be attractive enough for players to actually remain there.

Higher-value players in particular have, over recent years, partly migrated to unlicensed offers. If regulatory restrictions cause certain players to leave the legal market, we lose precisely the environment in which player-protection rules can be enforced.

A player gambling on the black market gains nothing from a theoretically perfect German stake limit.

Andreas: Then let’s measure that argument rather than simply believe it.

If higher stake options improve channelization without substantially increasing problematic gambling behavior, that is relevant for regulatory policy.

If, on the other hand, they merely increase losses and harmful behavior without bringing players back from the black market, that is equally relevant.

So the right question is not:

“Are €5 stakes good or bad?”

The right question is:

“Which regulatory framework minimizes overall harm?”

That is a much more difficult question.

But it is also the one we should be asking.

Andreas: Not on the basis of the data currently available.

I would propose something else:

Measure it.

We now have a regulatory change. In effect, we also have a real-world experiment.

Over the coming months, we should track indicators including the average stake per spin, the proportion of spins above €1, the distribution of higher stakes, losses across different player segments, developments among particularly intensive players, changes relating to the cross-operator deposit limits enforced through the LUGAS system and, to the extent it can be measured reliably, channelization.

Ideally, that data should not come from individual companies alone. It should be aggregated, anonymized and independently analyzed.

Then we would have a debate that could genuinely move us forward.

Andreas: Less talking past one another and more collaboration.

The signatories represent addiction-support organizations, researchers and self-help groups. We absolutely need their perspective.

At the same time, the industry possesses something that is enormously valuable to researchers: large-scale data on actual gambling behavior.

Instead of setting worst-case scenarios on one side against industry lobbying arguments on the other, we should combine those perspectives.

Addiction researchers formulate the hypotheses, regulators establish a controlled framework, and the industry provides anonymized behavioral data. Then we test what actually happens.

Andreas: Perhaps this:

Players have noticed the new freedom, but so far they are using it far less than the headlines might suggest.

Or even more simply:

€5 is now possible. That does not mean €5 has become normal.

Andreas: The concern for player protection is justified. The demand for transparency is justified. The demand for scientific evaluation is justified.

But anyone calling for science should also distinguish carefully between theoretical risk and observed behavior.

The open letter shows what can happen at €5 per spin.

The first market data shows what players are actually doing so far.

Around 95% of spins remain at €1 or below. Only a very small proportion reaches the higher stake ranges. And the average stake has, so far, increased only moderately.

That may change. Which is precisely why we should continue measuring it.

But regulation should be based neither on hope nor on fear.

It should be based on data.

And perhaps that is ultimately the point on which the GGL, addiction researchers and the industry should all be able to agree.

Data, not polemics.