KSA says Dutch deposit limits may push players offshore

The Netherlands’ regulated online gambling market has undergone several regulatory changes since its liberalisation in October 2021. Designed to offer robust consumer protection and promote responsible gambling, the legislation has introduced strict rules regarding advertising, player verification, and deposit controls. Among the most consequential measures came into effect in October 2024, when new deposit thresholds were imposed to reduce the financial harm associated with online gambling.

However, recent assessments by the Kansspelautoriteit (KSA) — the Dutch gambling authority — suggest that these well-intentioned restrictions may be producing unintended side effects. While the data confirms a decline in average losses per player, other indicators, such as a drop in legal operator revenues and increased interest in unlicensed platforms, raise questions about the broader market impact.

KSA observes fall in legal operator revenues

In its most recent report, the KSA disclosed that gross gaming revenue (GGR) from licensed operators has decreased by 8% since the implementation of the deposit limit rules in October 2024. Although the regulator maintains that the channelisation rate — the proportion of players using legal platforms — remains relatively high at 93%, a simultaneous increase in online searches for unlicensed gambling websites has raised concerns that some players may be shifting to the black market.

This shift, if it becomes entrenched, poses a risk to consumer protection, as unlicensed operators are not subject to Dutch laws governing advertising, responsible gambling, data privacy, or anti-money laundering (AML) standards.

Deposit limits: intended results and side effects

The core aim of the new regulation was to reduce gambling-related harm by restricting how much players could deposit monthly without further scrutiny. Under the revised rules issued by the Ministry of Justice and Security, players aged 18–24 must be contacted by operators if they attempt to set a monthly deposit limit above €150. For players aged 25 and older, the threshold is €350.

Separately, under KSA’s own supervision regime for net deposits, operators are obligated to reach out to young adults who deposit more than €300, and to adults aged 25 and over who deposit more than €700 within a calendar month. In these cases, operators must not only contact the player but also verify their financial situation to assess affordability.

According to the KSA, these interventions are producing measurable effects on player behaviour. The regulator reported that the percentage of players exceeding these thresholds dropped from 9.7% to 2.2% since the rules came into effect. Among players aged 18 to 24, the figure dropped more sharply — from 12% to just 1.9%.

Reduction in losses but questions remain

Beyond the threshold statistics, the KSA noted a 31% decrease in the average monthly loss per account, falling from €116 before the restrictions to €80 after their implementation. Moreover, high-risk gambling behaviour has significantly declined: previously, 4% of accounts incurred losses exceeding €1,000 per month; this figure has now fallen to just 1%.

While these outcomes suggest improved consumer outcomes, the regulator acknowledged that they may come at a hidden cost. In its formal statement, the KSA remarked:

“There is a possibility that heavy gamblers are now turning to illegal operators.”

This comment underscores a critical regulatory dilemma: measures that succeed in reducing harm within the legal market may simultaneously drive higher-risk players to offshore platforms that do not enforce such protections.

Rising interest in the illegal market

Although the KSA has not yet released concrete figures on actual migration to illegal websites, it confirmed a marked rise in search volume for the top 100 unlicensed gambling platforms. This metric serves as a proxy indicator for consumer interest in alternatives outside the regulated ecosystem.

The regulator’s concerns are compounded by the fact that unlicensed platforms can offer higher deposit and loss limits, as well as more aggressive promotional bonuses — features that are banned or heavily restricted under Dutch law. These incentives can prove especially attractive to high-stakes players, who may feel constrained by domestic rules.

Upcoming regulatory impact analysis

In a bid to provide more clarity, the KSA announced it will soon publish a comprehensive impact assessment that includes data on:

• Monetary channelisation levels
• Player retention within the legal market
• Migration trends to unlicensed operators
• The effect of the recent increase in gambling tax to 37.8%

The findings are expected to offer a clearer picture of how current policy instruments are affecting both the legal and illegal segments of the Dutch gambling landscape.

Legal market stability versus overregulation

The developments come at a delicate moment for Dutch policymakers, who are attempting to balance consumer protection goals with market sustainability. A steady decline in legal operator revenues could undermine the commercial viability of compliant platforms, especially if they are losing their high-value clientele to unregulated competitors.

Critics of the current deposit limit framework argue that overly restrictive thresholds may backfire, undermining the very policy objectives they are meant to serve. Advocates for reform have proposed a more data-driven, flexible risk assessment model, whereby deposit limits are personalised based on income or other affordability indicators, rather than using flat thresholds across all demographics.

The KSA’s delicate mandate

The KSA finds itself in a challenging regulatory position. On one hand, it must enforce the legal framework established by the Dutch government, including deposit limits and affordability checks. On the other, it must ensure that the regulated market remains attractive and competitive enough to discourage consumers from turning to unlicensed operators.

While the deposit limits appear to be effective in curbing excessive losses and protecting vulnerable users, the regulator’s own data now suggests that they may also be creating incentives for circumvention, particularly among high-risk players.

As such, the KSA appears to be taking a cautious approach — acknowledging the policy’s benefits, but also highlighting its risks and committing to further evaluation.

Implications for future policy

The debate now centres on whether the current deposit thresholds strike the right balance, or whether they need adjustment to better align with market realities. The upcoming impact study will likely inform potential policy amendments, but any change must also consider:

• The political and public appetite for tighter gambling controls
• The readiness of operators to adopt alternative affordability checks
• Technological infrastructure to personalise deposit limits

If consumer migration to the black market is confirmed to be substantial, Dutch lawmakers may face pressure to revisit the 2024 reforms in order to preserve the integrity of the legal system.

Conclusion

The introduction of strict deposit limits in the Netherlands’ regulated gambling market has undeniably contributed to significant reductions in average player losses and high-risk gambling behavior. These outcomes align with the core objectives of Dutch gambling policy — namely, protecting consumers and promoting responsible play. However, early indicators suggest that these reforms may also be driving certain players, particularly high-stakes gamblers, toward unlicensed operators operating outside of Dutch jurisdiction.

The Dutch Gambling Authority (KSA) has responsibly acknowledged both the successes and potential shortcomings of the new rules. Its transparency in reporting declining gross gaming revenues and rising interest in the illegal market signals a commitment to evidence-based regulation. As the KSA prepares to publish more comprehensive data in the coming weeks, policymakers will be faced with a critical challenge: how to preserve consumer protections without unintentionally weakening the licensed market or fuelling the growth of the black market.

Going forward, regulatory frameworks may need to evolve toward a more dynamic, risk-based model that takes into account players’ individual financial circumstances rather than relying solely on universal thresholds. Such a shift would require careful coordination between regulators, operators, and lawmakers. Ultimately, maintaining a high channelisation rate while minimising harm will depend on the ability to strike a measured balance — one that safeguards vulnerable players without pushing others outside the legal system.

FAQs

What are the new Dutch gambling deposit limits?
Players aged 18-24 must be contacted if they set limits over €150 per month, and those 25 and older if they exceed €350. Separate net deposit checks apply above €300 and €700, respectively.

When were these deposit rules introduced?
The deposit rules came into force in October 2024, as part of broader reforms to reduce gambling harm and improve affordability oversight.

Have the deposit limits reduced gambling harm?
Yes, average player losses have declined by 31%, and the percentage of players losing more than €1,000 monthly has dropped from 4% to 1%.

Are the rules affecting legal operator revenues?
Yes, the KSA reported an 8% decline in gross gaming revenue from licensed operators since the rules took effect.

Is there evidence of increased use of illegal gambling sites?
While no definitive data has been published, the KSA notes a rise in search volumes for the top 100 unlicensed gambling websites.

What is the channelisation rate in the Netherlands?
The KSA estimates a 93% channelisation rate, meaning that most Dutch online gamblers continue to use licensed operators.

Why is the KSA concerned about the black market?
Illegal operators do not follow Dutch rules on responsible gambling, making them riskier for consumers and undermining regulatory goals.

What actions must operators take under the new rules?
Operators must contact players exceeding monthly deposit thresholds and conduct affordability checks before allowing further gambling.

What further analysis is the KSA planning?
The KSA will publish an impact report including data on monetary channelisation and the impact of the recent gambling tax increase.

Could the deposit rules be amended?
Possibly. If data confirms increased black-market activity, regulators may revise the rules to ensure both protection and competitiveness.