Casinos without a German licence: which licence applies instead and what it means for withdrawals and complaints

A casino without a German licence is an online offer that holds no permit from the Joint Gaming Authority of the German Federal States (GGL) and is therefore not on its whitelist. A German gambling licence is based on the State Treaty on Gambling 2021 and, depending on the type of game, is issued by the GGL or by the federal states. For players, what matters with operators outside that list is which licence they name instead and what follows from it for withdrawals and the complaint route.

According to de.casino.guru, Bizzo, KatsuBet, Posido and Neospin accept players from Germany. None of them appears in the whitelist of 02.10.2026, neither under the brand name nor via domains or the operating companies. Their licences come from Curaçao, from the Comoros island of Anjouan, from Estonia and from Canada. Withdrawal limits, identity checks and disputes are therefore governed by the rules of these licensing bodies and by the operators' terms and conditions.

What “without a German licence” means: not on the GGL whitelist

Whether an operator holds a German permit is shown by a single source: the official whitelist that the GGL has published under § 9 (8) of the State Treaty on Gambling 2021 (GlüStV 2021) since 01.01.2023. Each entry names the organiser or intermediary, the type of gambling, the address, the sales territory, the competent authority and the websites; the list does not show a licence number. According to a GGL press release of 22.09.2026, 129 organisers and intermediaries hold a GGL permit, and 229 gambling websites are permitted in total. Permitted operators must state on their home page that they hold a state permit and which authority issued it.

A casino licence in the German sense, that is, a permit for online gambling, exists only for certain types of games: lotteries, sports and horse-race betting, online casino games, virtual slot games and online poker. The GGL itself has issued the permits for virtual slot games and online poker since 01.01.2023, while online casino games with a banker, such as roulette or blackjack, remain the responsibility of the federal states. A permit for virtual slot games or online poker is first granted for 5 years, and thereafter for 7 years. Anyone applying for a permit for sports betting, online poker or virtual slot games must have their registered seat in an EU or EEA state and, without a seat in Germany, must appoint an authorised recipient and representative in the country.

According to the GGL, an operator remains without a permit until its application has been examined, approved and the operator has been added to the whitelist. For data protection reasons, the authorities do not disclose whether an application has been filed. A seal in the footer does not replace this check: the GGL does provide permitted operators with its own inspection and permit seal, but describes checking the whitelist as the safest way.

Which licences the four operators name instead

The four brands are split between two main licensing bodies and two additional licences. According to casino.guru, Bizzo and KatsuBet hold a licence from Curaçao, Posido and Neospin one from Anjouan; casino.guru also gives Posido an Estonian licence and Neospin a Canadian licence from Tobique. All numbers are given by casino.guru, which marks them as “verified”; the two Anjouan numbers can also be checked in the public register. The table summarises the status as of 08.10.2026.

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For Bizzo and KatsuBet, the number currently cannot be checked with the regulator. The Curaçao Gaming Authority announced on 07.10.2026 that its online gaming portal will not return to operation. Since 24.12.2024, the Curaçao licence has been based on the LOK; according to the CGA, existing licences remain valid, and a replacement for the digital seal has been announced.

For the Anjouan licence, by contrast, there is a public register that can be searched by number, company or domain. Neospin is listed there with ALSI-202509073-FI2 and Metlait SRL, valid until 29.09.2027, with neospin.com registered as a domain. For Posido, ALSI-202411077-FI2 belongs to Stellar Ltd according to the register, but posido.com does not appear in any entry.

The additional licences do not hold up to every check either. The Estonian EMTA list of legal operators dated 01.10.2026 lists www.posido.com under Estolio Limited, but the Estonian MTR shows the operating permits HKL000355 and HKL000543 for this company, not HKL000354 as given by casino.guru. Bizzo appears in the same EMTA list under Moon Technologies OÜ. AskGamblers also names the Kahnawake Gaming Commission for Bizzo and PAGCOR for Posido; the Philippine authority, however, cancelled all online licences with effect from 15.12.2024.

Behind the brands are operators whose company names change depending on the source. For KatsuBet, lcb.org names Kika Technology B.V. instead of Scores55 Tech B.V.; for Posido, Stellar Ltd and Estolio Limited stand side by side. For each brand, the licence profiles of the 4 operators record licence, language and these discrepancies separately.

Withdrawals without a German licence: limits per brand

With operators holding a GGL permit, an open-ended bank guarantee of €5 million, which can be raised to €50 million, secures players' payout claims. If a player account is closed, the balance must be transferred within 5 working days at the latest, and fees for closure and withdrawal are not permitted. With the four brands, the terms and conditions determine how much is paid out per day, week or month and which documents are requested beforehand.

According to casino.guru, AskGamblers and lcb.org, Bizzo pays out at most €4,000 per day, €16,000 per week and €50,000 per month; according to casino.guru, winnings are not capped. The minimum withdrawal is €10 according to lcb.org, and €500 by bank transfer, which casino.guru confirms. According to lcb.org, the identity check takes up to three days; casino.guru flags an unreasonably short deadline for submitting documents as an unfair clause.

KatsuBet states its limits in its own terms in bitcoin: 0.14 BTC per week and 0.56 BTC per month, with amounts above that paid out in instalments. casino.guru, AskGamblers and lcb.org name €10,000 per week and €40,000 per month. The minimum withdrawal is €20. Before a withdrawal, the deposit must be wagered at least three times, ten times for table games and live casino. KatsuBet may request documents on identity, address and payment when an account is opened, before a deposit, before a withdrawal or once statutory or risk-based thresholds are reached; the terms do not name an amount. According to its terms, the check can take up to 30 working days.

Posido sets its limits by VIP level. At the base level Mortal, the operator's rules give €500 per day and €7,000 per month; at the highest level Poseidon, €1,500 per day and €20,000 per month. casino.guru gives the base-level figures, AskGamblers €500 per transaction and per day plus €10,000 per month. Requested documents must be provided within 30 days of the request.

According to casino.guru and lcb.org, Neospin limits withdrawals to €4,000 per day, €10,000 per week and €30,000 per month, with no cap on winnings. The minimum withdrawal is €20 according to lcb.org, where the identity check is said to take up to 30 business days.

Complaint route per regulator

If a withdrawal is not paid or an account is blocked, the first step with all four brands leads to the operator itself. What comes next depends on the licensing body, and this is where the regulators differ considerably: some prescribe a dispute resolution procedure, others treat complaints merely as tip-offs.

The Curaçao Gaming Authority does not mediate or decide disputes between players and operators and does not order compensation. It uses every submission as an indication of possible breaches of the LOK and gives no information on the status of investigations. A standardised form has been announced. For customers of Bizzo and KatsuBet, there is therefore no body at the regulator that decides on a claim.

Anjouan Gaming does not mediate itself either, but prescribes a fixed procedure. First, the complaint goes to the operator via the function in the seal, and the operator has 30 calendar days to reply. This is followed by alternative dispute resolution (ADR), in which licence holders must take part and whose costs the operator bears; the procedure is conducted in English. This applies to Neospin and, insofar as the Stellar Ltd licence covers the brand, to Posido.

In Estonia, problems with a listed operator that cannot be resolved with the organiser can be raised with the EMTA by e-mail; this applies to the two brands listed there.

For comparison: the Malta Gaming Authority accepts submissions from players itself through its Player Support Unit, for example on withdrawals, bonus terms, identity checks or account closure, and requires licence holders to engage a dispute resolution body. If that body decides in the player's favour, the operator has 20 days to comply. None of the four brands names an MGA licence; the complaint route via Malta is therefore not open to their customers.

What is missing: OASIS, LUGAS and the stake limit

The GGL permit comes with protection rules that an operator licensed in Curaçao, Anjouan or Tobique does not have to adopt. With permit holders, according to the GGL, the player is checked against the OASIS player exclusion file at registration and at every sign-in. A self-exclusion is possible there for at least 3 months, an exclusion requested by third parties for at least one year, both free of charge.

The LUGAS limit file monitors a cross-operator deposit limit of, as a rule, no more than €1,000 per month. For virtual slot games, the maximum stake is €1 per game as a rule; since 01.07.2026, the GGL has allowed tiered maximum stakes under conditions of up to €3 (from age 21) or €5 (after 90 days of unremarkable playing behaviour), limited until 31.12.2027. A game must last at least 5 seconds on average. In addition, there is the file against parallel play, which prevents anyone from playing with several operators at the same time. Each virtual slot game also needs its own permit before it may be offered.

What the four brands offer instead varies. According to AskGamblers, Bizzo has limits for deposits, stakes, losses and playing time as well as self-exclusion, but no cooling-off period and no connection to an exclusion register. KatsuBet lists on its own site limits for deposits, stakes, losses and session length, a cooling-off period and self-exclusion for a fixed period or indefinitely. According to AskGamblers, Neospin offers limits, self-exclusion, cooling-off and a self-assessment. For Posido, AskGamblers names only a loss limit, self-exclusion and a self-assessment; casino.guru warns that self-exclusion is severely delayed or impossible.