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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.

It requires operators to describe in detail how they will responsibly wind down their operations should their licence not be renewed or be revoked. Or if they decide to leave the market midway through the five years between renewals.

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It was found that “this group then self-reported significantly lower expenditure and harms [ … ] over the next two weeks”.  

They recommended banning direct marketing by operators and affiliates except for essential account or safety communications.

The committee also suggested a ban on inducements (free bets, sign-up bonuses) as these promotions stimulate betting activity and recruit new or lapsed customers.

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Dahms highlighted the significant dangers unlicensed operators pose to player protection and the overall integrity of the licensed market. He cited the absence of controls such as deposit limits, identity verification and player suspension tools. 

He also called for continued rigorous enforcement efforts alongside strict regulation to safeguard consumers, adding: “Anyone who wants to strengthen player protection must therefore consistently crack down on illegal services and strengthen legal ones.”

The DSWV said the findings should prompt a thorough reassessment of official black market size estimates in Germany.