Dutch regulator improves sports betting risk analyses

The Kansspelautoriteit (KSA), the Netherlands’ gambling watchdog, recently published findings from its investigation into how licensed online sports-betting operators manage integrity risk. The focus was on the procedures these operators use to identify, assess, and mitigate risks tied to match manipulation. The review reveals encouraging progress but also highlights persistent gaps and areas requiring further attention.

Context and purpose of the investigation

Under Dutch law, sports-betting operators holding a licence must carry out risk-analyses addressing the integrity of the sporting events they cover. These assessments are designed to help prevent match-fixing and other manipulation of betting markets. The KSA’s probe was triggered after reports to the Sports Betting Intelligence Unit (SBIU) signalled a possibly manipulated match. In response, the regulator examined four licensed operators’ risk-analysis frameworks to determine if they sufficiently recognised and acted upon manipulation risk.

Key findings: progress made

According to the KSA’s findings, the assessed operators generally meet expectations in conducting integrity risk assessments. This constitutes an improvement compared with previous reviews. The regulator observed that procedures for identifying and evaluating risks are now better embedded in the operator workflows. Operators are increasingly mindful of their legal obligation to monitor and report suspicious activity, and have strengthened their internal processes.

Areas for further improvement

Despite progress, the KSA emphasises that substantial room for improvement remains. Specific issues identified include:

• Insufficient granularity: Many assessments remain too generic, lacking detailed identification of particular risks associated with specific matches or events.
• Preventive measures: Although operators have introduced risk-mitigation mechanisms, the regulator found that documentation of those preventive measures is often lacking in depth or clarity.
• Reporting and escalation: There are gaps in how operators report suspicious triggers and escalate matters, potentially undermining timely intervention.

Why the regulator is concerned

The integrity of sports betting is vital to consumer protection, market trust and the reputation of both operators and the Dutch framework. Weak or inconsistent risk-analyses can create openings for manipulation, threaten fairness, and increase regulatory exposure. By holding operators accountable for robust systems, the KSA is reinforcing the broader integrity ecosystem surrounding sports-betting.

The regulatory framework

Under the Dutch Gambling Act and related regulations, licensed sports-betting operators must perform regular risk-analyses. These risk-analyses cover multiple dimensions: event manipulation risk, unusual betting patterns, geographic or circumstantial anomalies, and player or account-based risk indicators. The KSA’s SBIU collects signals of possible manipulation for follow-up, and the regulator retains supervisory authority to review operators’ risk frameworks.

What the four operators showed

In its review of the four selected licence-holders, the KSA found:

• The operators had implemented formal procedures for risk-analysis, including screening of sports events and monitoring of betting-patterns.
• The operators were aware of their reporting obligations when significant anomalies arise.
• However, the reports submitted to the KSA revealed that in some cases the operators’ internal assessments lacked clear documentation of how specific risks were weighed and how mitigating measures were applied.

Detailed challenges

Insufficient specificity of risk factors
Some assessments grouped many matches together under broad “sports-event risk” categories rather than examining each event individually. This approach can miss nuances: for example, a low-profile match may present higher manipulation risk due to its relative obscurity, even though high-profile matches get more attention. A more event-specific approach could make the risk-analysis sharper.

Documentation of preventive measures
When operators identified higher-risk matches, they sometimes failed to clearly document follow-up actions or how preventive controls were applied. Examples include: which monitoring thresholds were triggered, how betting limits or suspensions were applied, whether alerts were generated and how they were escalated.

Reporting delays or inconsistencies
In some cases, the KSA noted that operators did not always report suspicious signals to the SBIU with sufficient clarity or promptly. Some signals were flagged internally but not elevated externally; in others the reasoning for not reporting was not clearly documented.

Implications for the market

For the licensed operators, the messaging is clear: meeting the legal obligations of risk-analysis is necessary but not sufficient. The quality of that work—not just having procedures, but executing them effectively and documenting comprehensively—is critical. For the regulator, achieving higher consistency across operators will help ensure a level playing field and reinforce market integrity. For the sports-betting market more broadly, stronger controls help maintain public confidence and guard against reputational damage.

Regulatory next steps

According to the KSA, the following steps are expected:

• The regulator will engage with licence-holders to raise awareness of the identified gaps and support implementation of improvements.
• The KSA may issue formal guidelines to clarify expectations on how risk-analyses should be conducted, documented and reported.
• The regulator intends to increase supervisory scrutiny, including random requests for operators’ risk reports and follow-up audits.
• The KSA will liaise with the Ministry of Justice and Security to explore standardisation of methods and possible regulatory enhancements.

A broader view: Integrity and risk in Dutch sports betting

While this investigation focused on integrity risk analysis, it sits within a wider regulatory ecosystem. The Netherlands’ regulated online gambling market commenced in October 2021, and the KSA has since been sharpening its oversight of operator conduct, player protection, anti-money-laundering (AML) compliance and illegal-market erosion. For example, the KSA’s “Match-Fixing Trend Analysis 2024” found that reports of potential manipulation rose from six in 2023 to 13 in 2024, across eight licence-holders. The regulator issued four warnings in that context.

These developments reflect the dual challenge of promoting a safe regulated environment while minimising risks to consumers, sport integrity and the business ecosystem.

Industry reaction and significance

Operators in the Dutch market will take note of the KSA’s findings. The fact that the regulator acknowledged progress is positive, but the calls for stronger specificity and documentation underscore that compliance will become more exacting. From a competitive standpoint, operators that demonstrate rigorous integrity-risk frameworks may gain reputational advantages. From a regulatory standpoint, the KSA is signalling that simply having systems in place will not suffice; detailed execution matters.

Practical advice for operators

Operators subject to similar regulatory frameworks or licence-holders in other jurisdictions may draw lessons from the Dutch experience:

• Ensure that risk analyses are event-specific rather than generic.
• Document clearly the assessment of each risk, the reasoning behind conclusions and the preventive measures applied.
• Maintain logs of thresholds, alerts, investigations and escalation decisions.
• Ensure that reporting obligations are understood and embedded in the compliance workflow.
• Keep an audit trail showing review and improvement of risk-analysis methodologies.

Conclusion

The KSA’s review of integrity risk-analysis in sports betting highlights a sector in transition. Licensed operators in the Netherlands are generally improving their compliance, but the regulator’s findings emphasize that the work is not complete. As sports-betting markets become more complex and manipulation risks evolve, the demand for robust, well-documented and timely risk-analyses will intensify. For operators, regulators and other stakeholders in the ecosystem, the message is clear: depth and detail matter when safeguarding integrity in gambling.

FAQs

What is the Kansspelautoriteit?
The Kansspelautoriteit (KSA) is the Dutch regulatory authority responsible for supervising gambling activities in the Netherlands, including online sports betting, licensed operators and consumer protections.

Why did the KSA investigate sports-betting risk analyses?
The investigation was triggered by reports submitted to the Sports Betting Intelligence Unit (SBIU) of a potentially manipulated match and aimed to assess whether licensed operators are properly identifying, analysing and mitigating integrity risks.

What are the main obligations for operators under the Dutch framework?
Licensed sports-betting operators must carry out risk-analyses of the betting events they cover, implement preventive measures, monitor suspicious patterns, report signals of manipulation and maintain compliance with the Gambling Act and associated rules.

What progress has been found by the regulator?
The KSA found that operators are generally meeting expectations in conducting integrity-risk assessments and have strengthened their procedures compared to earlier evaluations.

What shortcomings did the KSA identify?
The main gaps include insufficient specificity of risk analysis (many assessments are generic rather than event-specific), weak documentation of preventive measures, and inconsistent reporting or escalation of suspicious signals.

Why is event-specific risk analysis important?
Because manipulation risk can vary significantly between matches and sports, a generic category-level analysis may miss higher-risk individual events. Event-specific scrutiny enables more targeted preventive actions.

How might operators respond to the KSA’s findings?
Operators should review and upgrade their risk-analysis frameworks, increase documentation and audit trails, ensure timely reporting of signals, and align their internal processes with regulatory expectations for depth and clarity.

Does this investigation affect only the Netherlands?
While the findings are specific to the Netherlands, they carry broader significance for other jurisdictions where sports-betting integrity, operator risk frameworks and regulatory oversight are evolving. Operators globally may draw lessons from the Dutch experience.

What are the implications for sports integrity?
By reinforcing robust operator due-diligence and risk management, the regulator helps reduce opportunities for match-fixing and manipulation, which in turn protects the integrity of sport, the fairness of betting markets and consumer confidence.

What happens next in the regulatory process?
The KSA plans to engage with operators to address the identified gaps, issue further guidance or guidelines, perform random supervisory checks of risk-analysis reports, and collaborate with the Ministry of Justice and Security to consider standardisation of methods.