LUGAS, the cross-state gambling supervision system. While the OASIS blocking system regulates general market access, LUGAS controls the detailed financial and time parameters of online gambling. It thus functions as the operational heart of preventive regulation. In the evaluation of the State Treaty on Gaming in 2026, LUGAS will play a decisive role, as its functionality will determine whether the German protection mechanisms have the desired steering effect or provoke unintended evasive maneuvers.
LUGAS connects all licensed providers in real time to a central database that maintains two essential files: the limit file and the activity file. The aim of this architecture is to prevent risky gambling behavior in advance through systemic barriers rather than addressing it retrospectively through intervention.
The legal and regulatory framework
The legal basis for LUGAS is, in particular, § 6c of the GlüStV 2021. The legislator has stipulated that a central file must be maintained to monitor the cross-provider deposit limit. This regulation is a response to the realization that isolated limits at individual providers in the digital world could easily be circumvented by opening multiple accounts.
The core of the system is the cross-provider deposit limit of generally 1,000 euros per month. This amount is not an arbitrary value, but represents an attempt to strike a balance between protecting the vast majority of players from excessive debt and maintaining a certain market attractiveness. In the 2026 evaluation, this very value will be put to the test: Is it low enough to prevent addiction, but high enough to keep players with purchasing power in the regulated market?
How it works: limit file and activity file
Technically, LUGAS is a complex real-time data mirror. The system is divided into two functional areas:
The limit file: This is where a cross-provider monthly deposit limit is stored for each player. Before a provider accepts a deposit, it must check with LUGAS to see whether the player's individual limit still allows for any leeway. If the limit has been exhausted, the transaction is blocked by the system.
The activity file: This file is used to enforce the ban on parallel play with multiple providers. As soon as a player logs in to a provider and receives “active” status, the provider reports this to LUGAS. This makes it technically impossible to log in to a second provider at the same time. After the gaming session has ended, a waiting period (cool-off phase) is triggered before it is possible to switch to another portal.
The evaluation assesses the technical stability of this data exchange. System failures or delays in the transmission of activity status immediately lead to game interruptions and user frustration, which jeopardizes the acceptance of the legal market.
LUGAS as an evidence-based indicator of addiction prevention
From a scientific point of view, LUGAS is a valuable tool for evaluation, as it provides reliable mass data on real deposit behavior for the first time. In 2026, the experts will have access to anonymized data sets that answer the following questions:
Utilization rate: What percentage of players actually reach the €1,000 limit? This provides information on whether the limit affects a broad mass or only a small high-risk group.
Effectiveness of increase requests: Under strict conditions (credit check, monitoring), the State Treaty allows limits of up to €10,000 or, in individual cases, even €30,000 (§ 6c). The evaluation will analyze how many players apply for these increases and whether providers are adequately fulfilling their verification obligations.
Prevention of parallel play: The activity file provides data on how often players attempt to be active with different providers at the same time. This is an important indicator of impulsive gaming behavior.
Game speed and the “five-second rule”
A specific element of German regulation for virtual slot games is the provision under Section 22a (6) GlüStV: A game round must last at least five seconds on average. In addition, the reels must rotate for at least 2.5 seconds. This time extension is intended to reduce the frequency of events and thus reduce the potential for addiction, as high game speed has been shown to promote a loss of reality.
The 2026 evaluation will examine whether this regulation has achieved the desired reduction in the rate of loss. Critics argue that this artificial slowdown massively impairs the gaming experience compared to international standards and thus jeopardizes channeling. The experts will have to examine whether the protective effect justifies the price of reduced market attractiveness.
The impact on channeling
The central area of tension with LUGAS lies in the channeling rate. A player who is blocked by the €1,000 limit or finds the five-second waiting time annoying will find immediate alternatives without any restrictions on the unregulated black market (offshore providers).
The evaluation must therefore clarify whether LUGAS leads to the protection of vulnerable players or whether it tends to cause high-revenue players—who are essential to the economic viability of the legal market—to migrate to the unregulated space.
This “channeling paradox” is the most difficult part of the assessment. Perfect player protection on paper is of little use if the target group leaves the system.
Individual limits and the credit assessment process
The evaluation will focus in particular on the processes for increasing limits. The legislator requires a “review of financial capacity” for this purpose. In practice, this often means submitting proof of income or credit reports. Scientists will have to investigate whether these hurdles are perceived as discriminatory or too invasive. From a data protection perspective, processing this highly sensitive financial data in connection with gambling behavior is a balancing act. The evaluation will assess whether providers apply uniform and legally compliant standards in this area.
Data protection and IT security
Since LUGAS processes an enormous amount of personal data, the integrity of the system is a key factor. The evaluation also includes reviewing data minimization and access authorizations. A data leak in such a central system would have fatal consequences for trust in state supervision. The GGL, as the coordinating authority, is responsible for demonstrating compliance with the highest IT security standards.
International comparison and special approach
In the European context, the German LUGAS model is being closely watched. While countries such as the UK and Denmark tend to rely on the personal responsibility of providers and their individual algorithms for early detection, Germany has chosen the path of state centralization. The 2026 evaluation will determine whether this technocratic approach is more efficient than decentralized solutions. The question is whether Germany is setting a gold standard for digital player protection or isolating itself with overly complex systems.
Conclusion
LUGAS is much more than a technical database; it is the digital control instrument of a state that claims to monitor online gambling seamlessly. The 2026 evaluation will show whether the harsh interventions in the mechanics of gambling and the financial freedom of citizens have had the promised preventive effect.
The results will form the basis for the next generation of gambling regulation. If the data shows that channeling through LUGAS is suffering massively without a decrease in addiction rates, a political discussion about adjusting limits and game speeds will be inevitable.
However, if channeling rates remain stable, LUGAS could serve as a successful model for modern, data-driven supervision.
Read the third part of our series on the evaluation of the State Treaty on Gaming here.
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