VNLOK reports illegal gambling ads remain widespread on Meta platforms

Dutch trade association VNLOK says Facebook and Instagram users in the Netherlands continued to encounter substantial volumes of gambling advertising linked to operators without a Dutch licence during May and June 2026. The findings are based on VNLOK’s periodic review of Meta’s advertising repository and form part of a broader dispute over how illegal gambling promotions are identified and removed on social media.

According to VNLOK, between 94% and 97% of gambling advertisements reaching Dutch users during the two-month period were associated with operators that did not hold a Dutch gambling licence. The organisation has presented the findings as evidence that post-publication moderation may not be sufficient to prevent exposure to unlicensed gambling offers.

VNLOK has also said it is pursuing legal action involving Meta and has submitted a complaint to the European Commission. The trade association is calling for stronger verification of gambling advertisers before advertisements aimed at Dutch consumers are allowed to appear.

Meta advertising library review highlights scale

VNLOK said its analysis focused on Facebook pages advertising using casino-related search terms. Rather than limiting the review to pages that were clearly identifiable as gambling businesses the organisation examined a broader range of pages that were carrying gambling advertisements.

The association said many of those pages did not appear to be gambling providers on the surface. According to VNLOK the pages were spread across more than one hundred categories including fan pages; municipal pages; marketing agencies; entertainment websites and personal blogs.

VNLOK said this fragmentation creates difficulties for enforcement because an advertiser may operate through a page that gives little indication of its underlying activity. It also argued that advertisers can establish another identity after an account or page has been removed.

“The Facebook pages are emphatically not recognisable as gambling providers. They fall into more than a hundred different categories: from fan pages, municipality pages and marketing agencies to entertainment websites and personal blogs. “This fragmentation makes detection at page level difficult and allows advertisers to continue under a new identity immediately after a removal.”

The figures published by VNLOK show that 697 Facebook pages carrying gambling advertisements were identified in May. That number increased to 3,237 in June.

Among advertisements associated with identified Facebook pages VNLOK said 96.0% in May and 98.8% in June directed users toward unlicensed operators. The organisation also examined 65,000 gambling advertisements with the largest reach. It classified 96.5% of those advertisements in May as illegal and 93.7% in June as illegal.

These figures are VNLOK’s own classification based on its methodology. They should therefore be understood as findings reported by the trade association rather than an independent judicial or regulatory determination that every advertisement identified was unlawful.

Rapid turnover creates enforcement challenge

VNLOK’s analysis also focused on how long advertisements remained online. It said gambling advertisements were visible for an average of 1.58 days in May compared with two days in June.

The majority were live for much shorter periods. VNLOK reported that 76% of the advertisements recorded in May remained online for less than one day. In June the corresponding proportion was 65%.

The association said Meta removed 11% of more than 60,000 illegal advertisements identified in May and 15% in June. Although that represented an improvement according to VNLOK it argued that removal after publication may still occur only after an advertisement has already generated significant reach.

This distinction is central to the dispute. A moderation system that removes problematic content after it has circulated may reduce the duration of exposure but may not prevent users from seeing the advertisement in the first place.

For VNLOK the key issue is therefore not only the number of advertisements eventually removed but the speed at which the advertisements can be created, distributed and replaced.

VNLOK points to cloaking and Telegram redirects

The association also described several techniques that it says are being used to make illegal gambling advertising more difficult to detect.

One method identified by VNLOK is cloaking. In the organisation’s description of the practice different users may receive different landing pages depending on factors such as timing or demographic characteristics. A person outside the intended target group could be shown a false error message while a potential player could be directed toward a page designed to promote an illegal gambling application.

VNLOK said Telegram was another route identified during its June analysis. Under the model described by the association a Facebook advertisement directs users toward a Telegram channel that promotes exclusive bonuses. A bot can then provide access to a mini-application that functions as an online casino outside the immediate environment of the advertising platform.

The association also reported instances in which established Dutch gambling brands were allegedly used in advertising without authorisation in order to create familiarity or trust before users were directed elsewhere.

Because these are allegations contained in VNLOK’s research the individual campaigns and techniques should not be taken as evidence of conduct by a particular operator unless separately established.

Legal action against Meta

VNLOK announced in June 2026 that it intended to take legal action against Meta while also lodging a complaint with the European Commission. The organisation said it wants gambling advertisers targeting Dutch consumers to undergo licence verification before campaigns are published rather than relying primarily on subsequent removal.

VNLOK has framed the dispute around consumer protection and the enforcement of the regulated Dutch gambling market. In its June statement the association said it believed the scale of illegal advertising justified stronger measures under the European Union’s Digital Services Act.

The broader European regulatory environment is already placing significant attention on the responsibilities of very large online platforms. Meta’s Facebook service is designated as a very large online platform under the DSA and the European Commission has ongoing enforcement activity involving Meta.

A separate Dutch court dispute also illustrates how Meta’s platform practices can become subject to detailed judicial scrutiny under European digital rules. In 2025 the Amsterdam District Court found aspects of the design of Facebook and Instagram to be inconsistent with the DSA in a case involving user choice over recommendation systems. The Amsterdam Court of Appeal subsequently increased the maximum penalties linked to compliance measures to €10 million.

Dutch gambling advertising rules remain strict

The Netherlands has comparatively strict requirements concerning gambling advertising, particularly where younger adults are concerned. The Dutch Gambling Authority, known as the Kansspelautoriteit or KSA, states that gambling operators may not direct advertising toward people aged 18 to 24. The regulator also applies additional requirements to advertising practices and responsible gambling measures.

Recent regulatory activity shows that these restrictions remain an active compliance issue. In 2026 the Ksa addressed marketing incidents involving licensed operators where advertising was visible to vulnerable groups including young adults.

Academic research using Meta’s advertising repository has likewise examined compliance among Dutch gambling advertisements. A study of 277 advertisements found that 7.3% of advertisements from online gambling licensees and 29.8% from land-based licensees included prohibited targeting criteria covering people aged 18 to 23. The study also noted important limitations in how Meta’s age-based reach data align with the Dutch legal definition.

These findings provide additional context for VNLOK’s argument that advertising controls on social platforms deserve close scrutiny. They do not, however, establish that all gambling advertisements identified by VNLOK were unlawful or that any particular advertiser acted improperly.

A wider debate over platform responsibility

The dispute also comes against a wider European debate over the responsibilities of online platforms when illegal or deceptive advertising is distributed through their services.

A notable French case involving the Barrière brand resulted in a January 2026 ruling by the Paris Court of Appeal concerning fraudulent gambling advertisements appearing on Facebook, Instagram and Messenger. The court ordered Meta Platforms Ireland Limited to maintain targeted filtering measures covering certain advertisements promoting online gambling and reproducing the Barrière trademarks when published by unauthenticated advertisers. The ruling followed evidence that at least 2,400 advertisements had been identified during checks carried out in January 2024.

That case is materially different from the dispute described by VNLOK because it concerned trademark misuse and specific filtering criteria rather than a general finding covering illegal gambling advertising in the Netherlands. Nevertheless it demonstrates that courts can impose targeted measures on platforms where the relevant legal conditions are satisfied.

What VNLOK wants Meta to change

VNLOK’s main proposal is a shift from removal after publication toward verification before publication. The association says advertisers running gambling campaigns aimed at Dutch users should demonstrate that they hold the required licence before an advertisement is distributed.

It also wants stronger detection of methods such as cloaking and redirects through messaging services. According to VNLOK these techniques can make conventional page-level moderation less effective because the visible identity of the advertiser may not match the commercial destination shown to a prospective customer.

The association has additionally called for stronger enforcement against intermediaries that facilitate access to unlicensed gambling offers. Its position is that effective consumer protection requires attention not only to gambling operators but also to the wider advertising infrastructure through which promotions can reach consumers.

The significance for the Dutch market

The issue is commercially significant because the visibility of licensed gambling brands can be affected when illegal operators compete for the same online audience.

VNLOK has argued that a large illegal advertising presence could undermine the objectives of the regulated market if consumers are repeatedly directed toward offers outside the Dutch licensing framework. The association has linked that concern to player protection, advertising compliance and the credibility of the legal market.

At the same time the dispute remains an active legal and regulatory matter. Claims made by VNLOK should therefore be distinguished from conclusions that may ultimately be reached by a court, the European Commission or another competent authority.

Conclusion

VNLOK’s latest review places renewed attention on the difficulty of controlling gambling advertising on large social media platforms. Its reported figures for May and June 2026 suggest that unlicensed gambling promotions can appear at considerable scale while remaining online for relatively short periods. In VNLOK’s view the speed of campaign turnover and the use of indirect or deceptive distribution methods can make retrospective moderation less effective.

The wider regulatory landscape shows that digital advertising enforcement is becoming increasingly focused on platform systems, advertiser verification and the practical ability of users and authorities to identify unlawful content. The Dutch gambling market is particularly sensitive to these questions because advertising rules are closely connected to consumer protection requirements and restrictions concerning young adults.

For Meta the challenge is not limited to removing individual advertisements. The wider question is whether platform controls can identify risky campaigns quickly enough to prevent unlawful offers from reaching consumers. For VNLOK the preferred solution is clearer pre-publication verification and more proactive detection.

As the association’s legal action and European complaint progress their outcomes could add further clarity to the responsibilities of social media platforms in relation to gambling advertising. Until the relevant proceedings reach definitive conclusions the reported allegations and classifications should remain attributed to VNLOK while the underlying evidence and regulatory questions continue to be examined.

FAQs

What is VNLOK?
VNLOK is a Dutch trade association representing licensed online gambling operators and related interests in the Netherlands.

What did VNLOK report about gambling advertising on Meta?
VNLOK reported that a very large share of gambling advertisements reaching Dutch users in May and June 2026 were linked to operators it classified as unlicensed.

How many Facebook pages did VNLOK identify?
VNLOK reported identifying 697 Facebook pages carrying gambling advertisements in May and 3,237 in June.

What percentage of the highest-reach ads did VNLOK classify as illegal?
VNLOK said 96.5% of the 65,000 highest-reach gambling advertisements reviewed for May were classified as illegal while the June figure was 93.7%.

What is cloaking in online advertising?
Cloaking is a technique in which different users may be shown different content or landing pages depending on characteristics such as timing or audience profile.

Why does VNLOK want advertiser verification before publication?
VNLOK argues that verifying gambling advertisers before campaigns go live could reduce the time during which unlawful promotions are visible to consumers.

Are gambling advertisements allowed in the Netherlands?
Gambling advertising is permitted under specific conditions in the Netherlands but licensed operators must comply with strict advertising rules including restrictions concerning young adults.

What is the role of the Kansspelautoriteit?
The Kansspelautoriteit is the Dutch gambling regulator. It supervises compliance with gambling legislation and advertising requirements.

Has Meta faced similar legal scrutiny elsewhere?
Yes. In France the Paris Court of Appeal issued targeted filtering measures involving advertisements that reproduced Barrière trademarks in connection with online gambling promotions.

Has Meta faced Digital Services Act scrutiny in Europe?
Yes. Meta is subject to enforcement under the EU Digital Services Act and European authorities have taken action concerning aspects of its platform operations.