Dutch License Renewal Scramble: Operators Face New Exit Plan Requirements

The Dutch online gambling landscape is currently undergoing a period of intense regulatory pressure as the five-year anniversary of the market's re-regulation approaches. Operators that entered the legalized market in October 2021 are now facing the daunting task of renewing their licenses under much stricter conditions. The local regulator, Kansspelautoritet (KSA), has made it clear that the renewal process starting October 1, 2026, will be far from automatic. In a significant policy shift, the KSA now requires every applicant to submit a comprehensive exit plan, outlining exactly how they will wind down operations should their license not be extended.

Several prominent brands have already successfully navigated this hurdle. Holland Casino, Bingoal, and TOTO Online, which is owned by Nederlandse Loterij, have announced five-year license extensions starting October 1, 2026. TOTO remains the dominant market leader, while Holland Casino holds the seventh position in terms of market share according to Blask data. For these firms, the early approval provides a much-needed sense of stability in a market that has become increasingly volatile due to political and public frustrations regarding gambling advertising.

Numbers and facts

The economic environment for Dutch operators has toughened significantly. The tax rate on gambling activities was increased to 34.2 percent in 2025 and rose again to 37.8 percent on January 1, 2026. This fiscal pressure, combined with advertising bans, has impacted the legal market's competitiveness. VNLOK, the trade body for Dutch online gambling, reported that the black market accounted for approximately 25 percent of all gambling activity in 2025. Furthermore, the KSA noted that the legal market's share of Gross Gaming Revenue (GGR) dropped to about 49 percent early last year, raising concerns about the effectiveness of the current regulatory framework.

Not all major players are in the clear yet. BetCity, the third-largest brand acquired by Entain in 2023, has a license due to expire this October but has faced multiple regulatory setbacks. In March, the operator admitted to violating marketing rules concerning young adults. More recently, the KSA contacted BetCity regarding the illegal use of role models in advertisements during the World Cup. It remains to be seen if these infractions will jeopardize their renewal. Meanwhile, Unibet, the second most popular brand, has until June 8, 2027, to finalize its extension, though its parent company FDJ reported a regional revenue decline of 19.9 percent in the first quarter.

Background

The Dutch Remote Gambling Act (KOA) was initially met with great enthusiasm, but the subsequent "bombardment" of advertising led to a swift political backlash. A ban on the use of role models was approved in May 2022, followed by a ban on untargeted advertising in July 2023. By July 1, 2025, sports sponsorship by betting firms was also prohibited. The KSA is now doubling down on compliance, focusing heavily on anti-money laundering (AML) and counter-terrorist financing (CTF) risk analyses.

"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." - Representative of Kansspelautoritet (KSA)

The regulator has warned that insufficient explanations regarding past failures could lead to the denial of a permit or the imposition of severe restrictions. This stance puts pressure on brands like Kansino and Fair Play, whose licenses expire this October. Even bet365, ranked fourth in market share, must navigate these new requirements without public financial disclosures, as it remains a privately held company.

Why it matters for German players

For players in Germany, the Dutch situation serves as a benchmark for the future of European regulation. The strictness of the KSA mirrors the approach taken by the German Gemeinsame Glücksspielbehörde der Länder (GGL). German players should note that companies operating in both jurisdictions must adhere to the highest standards of player protection. The German Interstate Treaty on Gambling 2021 (GlüStV 2021) already enforces a 1,000 Euro monthly deposit limit and a 1 Euro stake limit for virtual slots, which are essential safeguards similar to those being tightened in the Netherlands.

If an operator loses its license in the Netherlands due to non-compliance or poor player protection, it is a significant red flag for its reliability in Germany. The GGL whitelist remains the only reliable source for identifying legal and safe casinos for German residents. Playing at MGA or Curacao licensed sites does not offer the same level of legal recourse or regulatory oversight as a GGL-licensed platform, which is integrated with the LUGAS system to prevent problem gambling.

What it means for GGL-licensed casinos

GGL-licensed operators can expect that the trend toward more detailed operational documentation, such as the Dutch exit plans, may eventually arrive in Germany. Transparency and a clean track record are becoming the primary currencies for securing long-term licenses in the EU. For German casinos, maintaining strict adherence to advertising codes and stake limits is not just about avoiding fines; it is about ensuring their survival in the next licensing round. The high taxation and advertising restrictions seen in the Netherlands could serve as a warning of how quickly market conditions can shift if the industry fails to self-regulate effectively.