Is Your Dutch iGaming License Expiring in 2027? Your Exit Plan Starts Now
From 1 January 2026, new requirements apply to applications for Dutch remote gambling licenses, including applications submitted by existing license holders seeking a follow-up license. One of the key requirements is a formal exit plan explaining how the operator would wind down its gambling activities in an orderly manner.
For operators whose current license expires in 2027, the requirement is already relevant. Preparing an exit plan well in advance gives operators time to assess their existing arrangements, identify gaps and ensure the plan reflects how the business actually operates.
What has changed in the Dutch regulation framework?
Since 1 January 2026, all Dutch remote gambling license applications and re-applications must include a formal exit plan as part of their submission.
Importantly, the KSA's process is not a simple license renewal: existing license holders must apply for a new license through the designated procedure.
For operators whose license expires in 2027, the practical message is straightforward: exit planning should form part of the broader licensing and compliance preparation, rather than being left until the final months before the application.
What must your Exit Plan demonstrate?
A credible exit plan must explain how the operator would manage the legal, financial, tax, organizational, technical and communication aspects of winding down its gambling activities. It should be practical, sufficiently detailed and consistent with the operator's actual business model.
Key areas are:
- Player protection and repayments: How outstanding player balances would be identified and repaid, including how the operator would handle cases in which repayment proves difficult.
- Financial and contractual obligations: How the operator would meet its outstanding obligations and manage the termination of relevant supplier and payment-processing arrangements.
- Communication and accessibility: How former players and the KSA would remain able to contact the operator during the wind-down, including the designation of an appropriate contact person.
- Data retention and the control database: How relevant records would remain available, secure and accessible, and how the operator would comply with applicable retention, archiving and transfer requirements.
- Operational execution: How the exit would be coordinated across the organisation, including responsibilities, timelines and the measures needed to fulfil outstanding obligations.
These elements should not be treated as isolated checklist items. They need to form a coherent plan that can be implemented under different exit scenarios. This includes the expiry or termination of a license and a decision to cease offering gambling activities.
Player Funds Protection & the Exit Plan
Player-funds protection is an important part of preparing for an orderly exit. Operators need to understand how player balances are safeguarded and how those funds would be made available for repayment if gambling activities ceased.
However, an exit plan must address more than the legal structure used to safeguard player funds. Operators should also assess whether their arrangements would work in practice. This includes access to funds, reconciliation of player balances, payment processes, contractual dependencies and the availability of relevant records.
EM Group can assist operators in reviewing the relationship between their exit plans, player-funds arrangements and wider operational and compliance frameworks.
Why start preparing now?
An exit plan is no longer a formality reserved for operators leaving the Dutch market. Its value lies in demonstrating that the operator has considered how it would protect players, meet outstanding obligations and manage an orderly stop of activities.
If your Dutch license will expire in 2027 and you would like help preparing your exit plan, our team in Amsterdam is ready to help. Get in touch.
Frequently Asked Questions
Do existing license holders need an exit plan when applying for a follow-up license?
Yes. The updated licensing policy rules require an exit plan as part of applications submitted from 1 January 2026, including applications by existing license holders seeking a follow-up license.
When should I start preparing my exit plan?
Starting well ahead of the application is advisable. It gives you time to assess your existing arrangements, identify gaps and coordinate the plan with your player-funds protection, contractual obligations, operational processes and other licensing requirements.
Does a player-funds foundation replace the need for an exit plan?
No. A suitable player-funds arrangement may support player protection during an exit, but it does not replace the broader exit plan or its other required elements.
Anna Amstill
I am an avid Blogger and Writer with more than 6 years of experience with Content Writing. An Online Marketing expert specializing in Blog writing, Article writing, Website content, SEO specific Keyword content and much more. Education B.A. - business management, York University, Canada, Graduated 2016.
