Netherlands KSA Reprimands Endorphina Over Presence on 28 Black Market Sites

The Netherlands Gambling Authority (KSA) is taking a firm stand, placing gambling industry suppliers under tighter scrutiny. Prominent game developer Endorphina is at the center of an investigation that could have far-reaching consequences for the European iGaming landscape. The core issue is the extent of control a software provider must maintain over the distribution of its products. When slots appear on illegal platforms, regulators lose their patience, as this undermines the entire licensing system.

The KSA gave Endorphina a two-week deadline to take adequate measures to prevent its games from appearing on unlicensed sites. This deadline expired on November 2, the same day the regulator made its investigation and binding instruction public. While no fine has been imposed yet, the threat remains. If the steps taken to remediate the situation are deemed insufficient, sanctions will follow. This case clearly demonstrates that monitoring online casino operators is no longer enough; game manufacturers are now firmly in the spotlight as well.

Numbers and facts

The KSA investigation spanned from January to September 2026. During this period, inspectors discovered Endorphina games on at least 28 separate unlicensed websites. Among the portals mentioned are names like luckygem.com and qbet.com. These sites were already known to the authority, some having been subject to penalty payment orders previously. The KSA emphasized that games remained playable on these black market sites across three waves of investigation, lasting until September 30, 2026.

A central point of contention is the corporate structure. Endorphina is split into two entities: one based in Malta and one in Cyprus. While Endorphina Malta serves the regulated Dutch market, the company argued that the binding instruction should not apply to this entity, as the regulator could not prove exactly where the games were supplied from. The KSA rejected this argument outright. The authority maintains that both entities should be capable of taking the necessary steps to prevent black market participation.

Background

Communications between the supplier and the regulator have been protracted, lasting over six months. The company was first notified on April 2 that its games had been found on sites unlicensed in the Netherlands. On May 14, the supplier issued a statement denying any intent.

"There is no evidence that we intentionally supplied games to illegal providers in the Netherlands." - Official Statement, Endorphina

The company often argues that games reach websites via B2B intermediaries, leaving them with limited control over the software's final destination. The KSA requested an internal investigation into the misuse of games by third parties. However, according to the KSA report, the results of this investigation were never received and therefore could not be considered in the decision-making process. This lack of cooperation appears to have exhausted the regulator's patience.

Why it matters for German players

For German players, this case serves as a vital cautionary tale. Playing on sites that do not hold a license from the Gemeinsame Glücksspielbehörde der Länder (GGL) exposes users to immense risks. The Interstate Treaty on Gambling 2021 mandates strict rules to protect players from addiction and fraud. These include the 1,000 Euro monthly deposit limit via the LUGAS system and the one-euro-per-spin limit for online slots. If a reputable manufacturer like Endorphina appears on unlicensed sites, it does not mean those sites are safe. On the contrary, without a GGL license, there is no guarantee of fair odds or the payout of winnings. German customers should always check the official GGL whitelist before opening an account.

What it means for GGL-licensed casinos

German casinos with a GGL license must be extremely careful when selecting their partners. The Endorphina case shows that regulators are willing to take action against providers who fail to manage their distribution channels. A casino partnering with a manufacturer that has a massive black market presence could find itself in the regulator's crosshairs. The GGL demands absolute transparency. Manufacturers must ensure their servers are only accessible to German players when legal requirements, such as the panic button and the five-second spin interval, are technically implemented. Cooperation with reputable partners is essential for maintaining a German license.