Progress of sorts is being made in the tortuous process of issuing betting licences in Germany. But it is definitely a case of one step forward, one step backwards, and a step to the side too.
Mid-November 2013 has seen all 43 of the second phase applicants sent information about how the process will proceed. Still no licences have been issued and none look likely to be issued before the end of 2013.

Back in March 2013 around 18 licence applicants were invited to interviews with the regulator. At the time it was assumed that these selected applicants were in line for the licences on offer, much to the disgruntlement of those operators not invited for interviews. But now it appears that no operator is in a favoured position and that none of the applications was completely satisfactory in meeting all the criteria. All 43 applicants will be sent specific details before January 2014 as to how their application needs to be updated and improved. The applicants will then have three months to complete the changes. All of this could take until April 2014. 

At that point the process of evaluating the applications will begin again.
There will still only be 20 licences issued but a ranking system will be applied if more than 20 applicants meet the licensing criteria. There will then be a ‘cooling off’ period of around two weeks before licences are granted to the successful applicants. 
“It could easily be 2015 before any operators ‘go live’ under their new licences in Germany and even before the point at which the licences are issued the legal cases will begin,” suggested Global Betting and Gaming Consultants’ director Lorien Pilling. 
In GBGC’s view there are several potential areas for legal challenge: 
• The initial deadlines to submit applications back in August 2012 were very short (three weeks) and discouraged some companies from applying. More than 12 months on, no licences have been issued and, in some regards, the process has gone back to the beginning with the news from November 2013. Some companies could feel aggrieved that the false deadlines prevented them from applying. 
• Discrimination:
(a) Some applicants for a Federal licence have been invited for interview, others have not. GBGC understands no further interviews will be held. Are interviewed applicants at an advantage over those not called for interview under the first version of the licensing process, especially as none of the applicants, interviewed or not, were deemed to have met all the criteria?
(b) Are licence holders in Schleswig-Holstein in an advantageous position when it comes to winning a Federal licence? 
• There are already more than 20 sports betting licence holders in Schleswig-Holstein. What is the status of these licences for those operators not ultimately selected for a Federal licence?
(a) This is already a ongoing issue of the principle of “coherence” at EU level – having differing regulatory regimes in place within the same country 
• The evaluation criteria used to select 20 winning applicants from all those who meet the criteria (potentially 43) will come under great scrutiny for any perceived favour or bias 
Such are the complications the Hesse Ministry of the Interior has created for itself in trying to award 20 sports betting licences, Germany could well have won another World Cup or two before it is all sorted out.