Comparison of UK and Germany's Gambling Addiction Laws Assignment

Comparison of gambling addiction policies in the UK and Germany, focusing on legal frameworks, approaches, and theoretical models.

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A Comparison Between The UK And Germany Based On The Policy Or Legislation Framework Of Gambling Addiction

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Rapid usage of mobile phones has enhanced the popularity of online gambling even if it is not a novel idea. However, the invention of smartphones along with getting easy internet access expanded the industry rapidly throughout the past few decades. Gambling is the act of abandoning something valuable in pursuit of something even more valuable. As a result, it is very common to see individuals with behaviour addiction to gambling or compulsive gambling. Gambling addiction, also known as compulsive gambling, is the urge to keep gambling despite the harm it does to a person's life. Similar to how narcotics or alcohol can do it, gambling also simulates the brain's reward system which ultimately leads to addiction. It is a serious condition that has destroyed many lives over the past years along with creating a negative impact on the overall economy. The governments of several developed nations are creating policies and laws to combat this addiction in addition to close friends and family members. Similarly, two of the developed countries that are focusing on reducing the number of gambling addicts are “The United Kingdom” and “Germany”. Both of these two countries legalised gambling in the past years. The UK was the first one to legalise it in 2005 (, 2020). On the other hand, Germany legalised gambling in July 2021 (, 2023). The UK imposed legislation or policy on both offline and online gambling. On the contrary, Germany focused more on online gambling instead of offline gambling. These laws are different depending upon both countries. However, a critical comparison is the only way to have a comprehensive understanding of the variations in the legislation or policies implemented by the two nations. The primary goal of the study is to assess and compare the differences between the laws or policies that have been enacted in the UK and Germany to combat gambling addiction. The major objective of this study is to compare and contrast the main gambling addiction laws and regulations in the "UK" and "Germany". Together with the shared terrain. Contrasting and discussing the two nations' various approaches to addressing gambling addiction. In addition to the adjustments made by the governments to address this behavioural addiction.


Main policies/legislation regarding gambling addiction in the UK and Germany

The main legislation regarding gambling addiction behaviour in the UK is the "Gambling Act 2005". This act came into operation on the first of September 2007. This law lays out the rules for controlling all forms of gambling in the "United Kingdom", including "arcades", "betting", "bingo", "casinos", "gaming devices", "society lotteries" as well as "online gambling" (, 2020). The Gaming Commission, which serves as the primary regulator, was also established, with its roles and goals defined. However, due to the increase in offline gambling, this law was amended in 2014 to include all online gaming businesses, regardless of where they are situated, in Great Britain (, 2020). Contrarily, gambling is devolved in Northern Ireland but forbidden across Great Britain. Likewise, the legalised framework of Germany regarding gambling addiction behaviour is the new “German Interstate Treaty on Gambling” or “ISTG” (, 2023). In reaction to the rising popularity of online gambling, the first treaty was created in 2012 (Banks and Waugh, 2019). Nevertheless, it was unable to secure the support of all states, therefore neither it outlawed nor made legal. However, the new treaty of 2021 allowed a variety of "online gambling activities" in "Germany" and included stringent guidelines for "gambling operators", including "restrictions on particular games", "deposit caps", "a ban on advertising" and required ID checks (Van Oort et al. 2022). This treaty is considered the legal framework in accordance with behavioural gambling addiction.

Differences between the two legal frameworks

In spite of the fact that both nations' laws aim to stop gambling from becoming a huge social and economic problem, there are still big variations between them. The country's history, culture and background is the main factor for the differences between the two laws. In the UK it can be seen that along with online gambling offline gambling is equally popular. On the other hand, it is clear that due to the quick development of technology and widespread access to the internet, online gambling is more common in Germany. Apart from this, the legal framework regarding gambling addiction has been present in the UK since 2005 (, 2020). On the contrary, the Government of Germany has been able to legalise the ISTG since 2021 only. Based on this fact it can also be stated that both governments focus differently on the gambling prospects throughout the country.

Comparative and dissimilar aspects of the two legal systems

As discussed in the above context there are significant differences that can be observed in the laws of the UK and Germany regarding gambling. The "Gambling Act 2005" was primarily made in order to restrict both offline and online gambling practices. However, this act was amended in 2014 due to the rise in online gambling (, 2020). Nonetheless, the laws governing traditional gaming stayed the same. On the other hand, the German government was able to legalise the ISTG in 2021 (Holznagel and Kalbhenn, 2021). As a result, this legal framework was established regarding the increase in online gambling. This legal framework does not concern any kind of offline gambling practices. It is majorly focused on online activity regarding gambling including "advertising about gambling", "particular game restrictions" and so on (Strohäker, 2019). There are some similarities between these two statutes, despite their variances, that should not be overlooked. The massive expansion of internet gambling led to the "Gambling Act 2005" in the UK being amended in 2014 (, 2020). It has some of the same factors that allowed the German government to legalise the ISTG in 2021. Along with this both of these legal frameworks focus on preventing the behavioural addiction of gambling through improvising different regulations and practices. In addition, both nations place a strong emphasis on reducing the detrimental effects of gambling addiction on behaviour in order to avoid disruptions in the economy.

Comparison and contrast the way the UK and the German government are dealing with gambling addiction

Gambling has both positive and negative sides, just like anything else. According to the report it can be seen that gambling contributes to the economy of the UK along with providing employment to approximately 100,000 people (, 2020). Along with contributing to other sectors such as sports, advertising as well as racing. However, it has also been seen that there are many risk factors involved in gambling. One of the major risks of gambling is addiction. Addiction, particularly gambling addiction, can ruin an individual's life beyond repair. According to research, it has been seen that it satisfies specific criteria of harm and makes up about “0.5% of the adult population” (, 2020). The number along with the percentage is rapidly growing throughout the past few years. As a result, the UK Government has made various policies and measures in order to deal with this kind of addictive behaviour. The “National Plan to Prevent Gambling Harms” was launched by the UK government in April 2019 and ran until April 2022. After this, the UK government also has plans for launching another gambling harm prevention framework for children and young people.

Apart from this framework the UK Government also focused on giving treatment and support to those who are considered gambling addicts. According to the data provided, the national helpline received 30,000 calls in 2017 and 2018, and around 8,800 persons received treatment through services financed by GambleAware (, 2023). The government has plans for also coming up with a new national helpline number along with individual treatment, group treatment, online treatment, residential treatment as well as peer support in order to minimise the impact of gambling harm or gambling addiction. According to the “negative reinforcement theory of addiction” it has been seen that in spite of the dangers, many nevertheless use gambling because they help them feel better from unwanted feelings or sensations like bad moods, tension, arousal, yearning, or withdrawal as well as satisfy their brain reward system (May, Aupperle and Stewart, 2020). Thus, it can be stated that people become more addicted to gambling due to seeking personal satisfaction by winning.

Similar to the UK Government, the German government has implemented a number of regulations and techniques to reduce gambling-related crimes and prevent the spread of gambling addiction. Apart from the ISTG, the German government focused mainly on preventing underage gambling. The ISTG proposed many regulations according to which if an individual wanted to create an account within the online gambling porters, they need to provide many identification documents only after that they can register on the portal to play the games. Apart from this the government also banned any kind of gambling advertisement on third-party portals in order to prevent adults along with children and young participants in society from the spider wave of gambling (McLoughlin and Heery, 2022). The regulations also include an online gambling time limit along with a monthly limit according to the will of the legislature. This reduces the time of overall online gambling which ultimately helps in preventing addiction to gambling.

Theoretical models

The "Gambling Act 2005" of the UK and the new “German Interstate Treaty on Gambling” are both legal frameworks that govern gambling behaviour within both countries. Accordingly, it can be stated that both of the legal frameworks do not follow any specific theoretical model. On the contract, it can be seen that both of the legal frameworks are a combination of these theoretical models. According to the "disease interactionist model", it can be seen both of the legal frameworks focus on preventing gambling addiction which can further be considered a disease (van Tongeren et al. 2020). On the other hand, as per the "symbolic interactionist model", symbolic interaction uses symbols stored in the mind to animate mutual meaning and values (Husin, Ab Rahman and Mukhtar, 2021). Both of the frameworks also use this theoretical model to analyse the interaction between gambling addicts and society. Along with this both of the legal frameworks also follow the "moral interactionist model" by ensuring that gambling is practised responsibly, with the proper safeguards and protections for society and customers (Anderson and Burchell, 2021). Lastly, they also follow the "behaviour interactionist model" (Li, 2023). Through this theoretical model, both of the legal frameworks understand the factors affecting individual characteristics and environment in order to be addicted to gambling.

Changes in theoretical models

As previously discussed in the above contest both of the legal frameworks are a combination of the four theoretical models. Nonetheless, both of these legal frameworks were primarily focused on one theoretical framework at the time they were legalised. However, over time the "Gambling Act 2005" act moved from the "disease interactionist model" to the other three theoretical models (van Tongeren et al. 2020). Similarly, the new “German Interstate Treaty on Gambling” improvised other three theoretical models along with the "symbolic interactionist model" (, 2023). The changes were needed due to the changes happening within the gambling industry because of the increase in online gambling. As a result, both governments implemented four theoretical models into their policies or legislations regarding gambling addiction. As stated by Husin, Ab Rahman and Mukhtar, (2021), after implementing this theoretical model both governments were able to control the immense growth of online gambling along with the decrease in the number of gambling addicts.


The UK needs to focus more on the rules and regulations regarding online gambling even after amending the "Gambling Act 2005" in 2014. Apart from this they also need to implement more legal regulations regarding the prevention of children and young people from gambling addiction. Whereas the German government needs to focus more on the self-regulation of the providers as it is not enough to just need the licence criteria. On the other hand, after considering all of the facts discussed above in the study it can be concluded that both of the legal frameworks of the UK and Germany focus on preventing the addiction rate of gambling through their legal frameworks. On the contrary, it can be said that even if both frameworks concentrate on the same goals, they nevertheless have distinctions. On a similar note, it has also been observed that both legal frameworks share the same theoretical models as well. However, it has also been observed that the German government has been more focused on safeguarding online gambling rather than offline gambling. Whereas the scenario is slightly different for the UK Government as the focus is both on safeguarding offline as well as online gambling. On a similar note, it has also been observed that UK Government provides treatment and support to those who are in need due to gambling addiction. On the other hand, the German government does not seem to be providing this kind of service to those who are in need. As a result, it can be clearly stated that there are many differences that can be seen between the UK and German government policies or legislative frameworks regarding gambling or gambling addiction.


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