The Kansspelautoriteit (KSA), the Dutch gambling regulator, has rolled out a significant update for operators in the Netherlands. By January 1, 2026, any company applying for a new remote gambling licence or seeking to renew an existing one must present a detailed “exit plan.” This plan is essential for outlining how a company would retreat from the Dutch market if they opt not to renew their licence after the obligatory five-year period.
As stipulated by the KSA, the exit plan must clearly detail the procedures an operator would implement to cease all gambling activities in the Netherlands and ensure a complete market withdrawal. Furthermore, operators are now required to submit a document that keeps the regulator informed of any changes to their policies or operations in a timely manner. This document must accompany a risk analysis that addresses compliance with anti-money laundering (AML) and counter-terrorist financing (CTF) legislation, specifically under the Act on the Prevention of Money Laundering and Terrorist Financing.
Failure to meet these new regulatory requirements could lead to the rejection of an operator’s application, a measure that applies even to companies with a history of holding a Dutch licence. The introduction of these measures aligns with the fourth anniversary of the Netherlands’ legal online gambling market, which began on October 1, 2021. Operators who were among the first to secure licences will soon face the end of their initial five-year term, with renewal applications due before October 2026 if they wish to continue operations within the country.
Renewing licences will involve a more rigorous evaluation process compared with first-time applicants. The assessment will include a reassessment of advertising strategies and policies focused on preventing gambling addiction, alongside the integration of a control database test. The KSA has also issued a stern warning to operators with compliance issues over the past five years, indicating that previous infractions will be scrutinized during renewal applications. These operators will need to demonstrate what lessons were learned from past mistakes and how they plan to prevent recurrence. Insufficient explanations may result in their permits being denied or subjected to more stringent conditions and restrictions.
Additionally, operators who fail to comply with enforceable court rulings during their reapplication process may be deemed untrustworthy, which also serves as grounds for rejection.
In August, the KSA acknowledged that a recent increase in gambling tax to 34.2% did not yield additional revenue. Instead, it led to a decline in gross gaming revenue for both the online and land-based markets. This financial obstacle highlights the challenges faced by the Dutch gambling industry in balancing regulation with market viability.
Critics argue that these new measures could deter new entrants and stifle innovation within the Dutch gambling market. By imposing stringent requirements, the industry risks alienating smaller operators who lack the resources to adapt swiftly to compliance demands. On the other hand, advocates for regulatory reform argue that these steps are necessary to create a safer, more transparent gambling environment. They believe that a stringent regulatory framework protects consumers and ensures that only the most reliable and ethical operators remain in the market.
Despite the challenges, some experts see this development as a positive move towards a more mature gambling market in the Netherlands. The requirement for an exit plan is seen as a way to ensure that operators remain accountable and committed to the integrity of the market. “The exit plan requirement is not just a bureaucratic hurdle,” they say, “but a necessary measure to ensure stability and consumer protection in the fast-evolving landscape of online gambling.”
Looking forward, the industry anticipates how these regulatory changes will shape the Dutch gambling market. While some operators might view these new requirements as a daunting challenge, others see it as an opportunity to prove their commitment to regulatory compliance and consumer safety. The coming months will reveal how these dynamics play out, impacting both existing operators and potential new entrants in the Dutch market.
