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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.

The regulator noted that several operators received “additional points for attention”, indicating that while these applicants met minimum legal thresholds, the KSA expected continuous improvements in compliance practices.

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The DOCV reinforced its calls for a unified federal licensing regime for online casino games and stronger enforcement mechanisms against illegal operators. 

An ongoing review of the Interstate Treaty on Gambling, which is meant to conclude by the end of this year, should introduce a nationwide licensing model for online casino games, the group added.

As part of the review, German regulators decided in July to lift the €1 staking limit on online slots, another signal that regulators are actively reassessing the framework ahead of the treaty’s formal review.