On the afternoon of 1 October, the Dutch gambling community came together at the KSA’s headquarters downtown in the Hague for a much-anticipated presentation on the forthcoming 2026 licence renewal regime – the set of rules that gambling operators in the Netherlands must follow in 2026 to renew their licences for online gambling services.
The tension in the room was palpable. Operators, lawyers,and regulators gathered in a large hall: 16 tables, two companies per table, with KSA staff mingling at the edges.
When the Dutch remote‑gambling market launched in 2021, licences were granted for five years. The first 10 operators – TOTO, FPO, Holland Casino, NSUS Malta, Play North, Tombola Malta, Hillside, Bingoal, Betent and LiveScore Malta (which then exited the market in November 2024) – all face renewal in October 2026.
With that date approaching, speculation had grown that the KSA would tighten rules – making the relicensing process laborious and punishing. Many feared a reset, rather than a renewal, that would overwhelm even well‑established operators.
‘Past behaviour’ requirement sparks concerns among operators
The anxiety was partly caused by statements made before 1 October. The KSA chair had hinted that it would look into past behaviour when considering new and reapplications for gaming licences.
In its public announcements, KSA said: “Providers that made mistakes in the past five years must explain during the application process how they have learned from previous mistakes and how they intend to prevent recurrence. If we find this explanation insufficient, the permit may be denied or additional conditions and restrictions may be imposed.”
Bjorn Fuchs, chairman of VNLOK – the Dutch iGaming trade body – confirms that wild rumours circulated among operators prior to the meeting.
“We [thought we] were going to be punished for bad behaviour. Maybe we get five years, maybe one year, maybe we lose it altogether. These were some of the concerns,” he says.
Operators also feared that every facet of their business would be re-scrutinised. Would new demands be imposed on advertising, addiction prevention, AML and player funds? Might entire chunks of existing policy be deemed insufficient?
What came out of the operator KSA licence renewal meeting?
But after the meeting, as Fuchs recalls: “There was a sigh of relief going through the room when it was presented,” although the tension was not entirely dispelled.
Rather than a crackdown across the board, what is emerging is a more regulated renewal framework.
Fuchs summarises: “If you have a clean sheet, there are some hoops, but for various modules you can just send a declaration which states that you’re compliant.”
He emphasises the new system will make burdens less demanding than before, but the new “exit plan” requirement and sharper duty‑of‑care definitions do bring some added complexity.
Justin Franssen, a regulatory lawyer and partner at Franssen Tolboom, likewise tells iGB the KSA is not imposing extreme hurdles on existing licensees, as some had feared would be the case.
Although new measures such as more comprehensive responsible gambling policies and civil judgment compliance are being introduced, these largely build on existing structures, he explains. “The gambling authority strives to make the reapplication process as smoothly as possible,” Franssen says.
The formal session on 1 October opened with KSA addressing submitted questions across various licensing modules. A detailed programme had been circulated in advance.
Operators asked pointed questions: How much weight will prior fines carry? How is behaviour/activity abroad assessed? When does the new licence take effect relative to the old one?
Various operators and law firms pushed hard for more clarity, Fuchs said, and the KSA acknowledged that need for clarity.
Unpacking the KSA’s exit plan requirement
Most notably, all submissions must now include the aforementioned exit plan – a new obligation that applies across the board. This requirement, intended to ensure orderly market withdrawal, marks 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.
In short, it is to ensure players are not left vulnerable in the event of sudden market withdrawal. This includes ensuring proper handling of player balances, communication strategies to customers, technical shutdown procedures and data retention compliance.
In another marked departure from previous practice, the breach-prevention module (overtredingspreventie) is no longer confined to new entrants. Existing licensees seeking renewal must now also submit detailed protocols on how they proactively prevent regulatory breaches.
Several modules, including those related to financial security, player fund provision and internal oversight, can now be approved through signed declarations rather than full evidence-based submissions. Should doubts arise, the KSA may demand supporting documentation.
Non-compliance with KSA licence renewal rules could end in licence revocation
Other areas are heading in the opposite direction. The Central Data Bank (CDB) module has seen a notable hardening of requirements: operators must now submit a detailed control plan, present evidence of system conformity and provide a test programme.
Meanwhile, advertising and recruitment remain documentation-heavy areas, showing little regulatory leniency amid public and political sensitivity about consumer protection and market integrity.
Background checks have also become more intrusive in the KSA licence renewal process. The reliability assessment now obliges applicants to disclose previously unreported persons – individuals who were involved with or connected to the gambling operation but were not disclosed in earlier applications – or past behaviour linked to the operation and to map out corporate and personal affiliations.
Perhaps most consequential is the now-strictly enforced clause on civil judgment compliance. Operators who have failed to comply with enforceable rulings – be they related to player winnings, losses, or data subject access requests – could have their licence revoked.
As Franssen warns: “If an operator does not comply with civil judgments, they will not get a licence. The licence can be pulled.”
Political pressure on the market
Overall, the feeling among operators is that the regulatory changes reflect a market recalibrated for oversight and accountability.
As chair of the trade organisation, Fuchs’ stance is a mix of cautious optimism and realism. In his view, many new demands are not radically burdensome.
He notes that operators may now submit declarations in many modules rather than full packages, reducing paperwork in some cases. The real burden falls on areas like exit planning and the finer detailing of duty of care.
But Fuchs worries about one big overhang for the online market: political pressure. He described how for years in the Netherlands, gambling had “no friends in politics” and was subject to opinion-driven restrictions by Christian and socialist parties.
Those parties, such as the Christian Union and SP, have steadily pushed for tighter regulations or even prohibition. The coalition politics of 2021, reliant on such parties, suppressed the fact-based dialogue and liberal push-back, Fuchs expressed. The result: increasing constraints and shrinking product flexibility for legal operators.
Deregulation in Netherlands is ‘unrealistic’
Fuchs believes a turning point came earlier in 2025, when Parliament and a government roundtable began acknowledging how large the unregulated market had become and how detrimental that is to regulation and player protection.
Anti‑gambling voices like national addiction rapporteur Arnt Schellekens – who has previously been very vocal about banning online play – have moderated, admitting that prohibition would only drive players towards the unregulated market.
“The National Rapporteur is not in favour of a gambling ban, because it would drive people into illegality,” Schellekens said recently. Fuchs thinks that outright deregulation is politically unrealistic, even if opposing parties gain influence.
Franssen accepts that new entrants to the market will face burdens – even more than in 2021 – but he doesn’t expect the KSA to place unachievable demands on existing licence holders.
He warns, however, of “overarching playing limits” in the pipeline. Currently, deposit limits are set operator‑by‑operator. A regime to enforce a limit across all operators would devastate monetisation, he said.
Overall, Franssen calls the market situation in the Netherlands “a death by a thousand cuts”. Some smaller operators, he predicts, will drop out or be consolidated.
No friends in politics – but hope
Gambling remains a topic fraught with moral questions in the Netherlands, and few parties risk openly embracing it. For the operators, the tax hikes and tightening of regulations reflect more political caution than logic.
The gaming tax, starting at 29% at market launch, has climbed to 34.2% and is expected to reach 37.8%. The media, social pressure and anti‑gambling campaigns reinforce a political narrative that gambling needs constant control, stakeholders tell iGB.
Fuchs argues that the political tide appears less venomous now, as serious attention is turning to illicit gambling growth and the limits of prohibition. Yet he is aware that “gambling has no friends in politics” – and that upcoming elections may again bring forward stricter stances rather than liberalisation.
Franssen echoes this: many of the restrictions, such as advertising bans and deposit limits, were quickly introduced after the 2021 launch in response to political backlash. Any operator considering entering the Dutch market now must weigh a difficult climate of political fragility, he explained.
Fuchs hopes that in the future, fact‑based regulation replaces stacking of new burdens. “If you keep squeezing the legal industry, people go to the illegal offering,” he adds.
Indeed, many in the sector point to the growth of the unlicensed or offshore market and remain skeptical of early KSA claims that channelisation was 80–20. He believes the illegal sector was always larger, and that recent tight regulation has driven more players outside KSA’s purview.
Still, the hope among operators is that if KSA gets relicensing right – clear, proportional, consistent – they may strengthen legitimacy and player trust in the long run and could gradually push out illegal operators.
On 1 October the Netherlands regulator assured operators that KSA licence renewal requirements would not directly banish those with previous violations. But will the new framework enforce tougher restrictions elsewhere?