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On February 14, 2025, the Dutch State Secretary for Legal Protection, Teun Struycken, outlined a new vision for gambling regulation in the Netherlands, prioritising consumer protection. The policy shift follows concerns that existing measures do not sufficiently mitigate gambling-related harm, particularly for minors and young adults.
The Bigger Picture:
A government review of the 2021 Remote Gambling Decree (Wet Koa) revealed increased participation in online gambling and a rise in problem gambling cases. This has prompted a comprehensive policy overhaul aimed at tightening controls and strengthening regulatory effectiveness, especially in the online gambling sector.
Why should you care?
The Dutch government's revised approach introduces wide-ranging reforms with serious implications for operators. Key measures under the new vision include:
- Enhanced duty of care requirements for operators, compelling a more proactive approach to player monitoring.
- Deposit limits tailored to an individual’s financial capacity, marking a notable departure from fixed or self-set thresholds.
- Further restrictions on gambling advertising, building on existing controls.
- An increased minimum age of 21 for accessing high-risk gambling products.
- Broader enforcement powers for the KSA, including blocking access to illegal gambling websites.
The Ministry of Justice and Security aims to implement certain measures ahead of a full legislative revision, expected by late 2025. Advertising restrictions and duty of care enhancements may be introduced sooner.
Key developments driving reform:
What is striking is how ongoing enforcement dynamics have shaped these regulatory proposals. Recent actions by the KSA have spotlighted compliance risks and appear to be directly influencing policy development. In Q1 2025 alone, the KSA undertook 12 enforcement actions, including warnings, fines and demands for corrective measures. This comes after a total of 59 enforcement actions were carried out in 2024. Key enforcement highlights include:
Advertising-related actions: The KSA issued eight warnings for breaches of advertising rules, including violations of the role model ban and instances of untargeted advertising. One ad was flagged for suggesting gambling as a way to escape financial hardship, a narrative considered misleading under Dutch advertising law.
Unlicensed operators: Winning Poker Network was fined €1.275m in January for offering gambling without a licence. Aggravating factors included charging inactivity fees and falsely suggesting legitimacy by referencing a foreign licence. Another enforcement action was when Sarah Eternal, which operates Casinosky, received a €900,000 fine for failing to block Dutch players.
Other enforcement actions: Other noteworthy enforcement actions include:
- February 19, 2025: The KSA took action against TonyBet for failing to provide customer service in Dutch, reinforcing the requirement for accessibility and consumer protection in the national language.
- March 5, 2025: A formal notice was issued over a breach of the autoplay prohibition in online gambling, highlighting continued vigilance over product design safeguards.
- April 9, 2025: A warning was issued to a gaming arcade for breaching the ban on the use of role models in advertising, underlining efforts to protect vulnerable groups, particularly young people.
- April 15, 2025: The KSA imposed its first fine under the enhanced duty of care rules, levying a penalty of €734,000, a clear signal of increased scrutiny of operator practices concerning player monitoring and intervention.
This evolving pattern suggests enforcement is not simply reactive but is actively guiding regulatory change. It reflects a more assertive stance from policymakers and a broader trend toward regulation by enforcement.
Key actions to remain compliant:
Given the regulatory direction of travel, operators must move quickly to reassess and strengthen their compliance frameworks. Key actions include:
- Reviewing and enhancing duty of care measures: Ensure systems are in place to proactively identify and assist at-risk players, with clear escalation procedures and real-time monitoring.
- Implementing robust affordability checks: Move beyond self-declared limits by verifying players’ financial capacity, particularly for high-risk gambling products.
- Auditing advertising practices: Scrutinise all marketing content for compliance with new existing rules, especially restrictions on role models, misleading messaging and targeting vulnerable groups.
- Tracking legislative and policy developments: Monitor updates on fast-tracked measures and adjust internal compliance protocols accordingly, ensuring agility in response to evolving rules.
Looking ahead:
The Dutch regulatory environment is moving decisively toward stronger consumer protection, with enforcement emerging as the principal lever for driving change. Operators must treat these developments as a call to action. What began as an evaluation of gambling harm has grown into a broader regulatory shift, increasingly shaped by real-time enforcement outcomes.
In parallel, the Netherlands’ call for coordinated EU action against illegal gambling markets could inspire similar initiatives elsewhere. As the line between enforcement and policy continues to blur, the Dutch case may well serve as a model for regulatory recalibration across Europe.
