VNLOK urges stronger action on illegal gambling

The Dutch Gambling Authority (Kansspelautoriteit, KSA) recently released its most comprehensive impact assessment to date regarding the effects of the regulatory updates implemented on October 1, 2024. The report reveals promising trends in player protection within the licensed online gambling sector. Among the most significant findings is a substantial reduction in the number of accounts incurring high losses.

As reported by the Dutch Gambling Authority (KSA), there has been a significant reduction in the number of user accounts incurring losses exceeding €1,000. The figure has declined by more than 75%, now representing only 0.9% of all accounts. This decline suggests that the newly introduced duty of care measures and enforced deposit limits are effectively curbing excessive gambling behavior among users who engage with licensed operators.

The number of gambling accounts per player also remains stable at an average of 2.4, dispelling earlier concerns about potential “hopping” behavior—where players might try to circumvent operator-specific limits by opening multiple accounts across different licensed platforms.

These indicators point toward a maturing and increasingly responsible legal market, where regulatory tools are beginning to shape player behavior in a positive and protective manner.

Rising illegal gambling activity raises new alarms

Despite the progress made in the legal market, the situation outside it remains alarming. The KSA's assessment paints a disturbing picture of a growing parallel ecosystem—one that operates beyond regulatory oversight. While licensed operators are subject to stringent rules, offshore and unlicensed providers continue to attract Dutch players, often with minimal barriers to access.

According to the KSA’s data, Dutch consumers are still spending roughly €0.50 of every online gambling euro on illegal websites. Even more troubling is the sharp rise in online searches for such platforms. Since the implementation of the stricter regulatory framework in October 2024, average monthly search volumes for illegal gambling sites have risen by approximately 23%, reaching nearly 1 million queries.

This trend suggests that a significant portion of players, especially those unwilling to comply with stricter regulations, may be migrating to unregulated platforms that do not adhere to any form of consumer protection or responsible gambling standards.

VNLOK sounds the alarm on vulnerable players

The Dutch association representing licensed online gambling operators, Vergunde Nederlandse Online Kansspelaanbieders (VNLOK), has voiced serious concerns about the growing presence of unregulated gambling platforms. The organization warns that unless swift and targeted enforcement measures are introduced, the protection of vulnerable players—including minors, young adults, and high-stakes gamblers—will be severely compromised.

VNLOK chairman Björn Fuchs stated that although the positive impact of the new rules is evident among legal operators, authorities and stakeholders must not ignore what is happening in the unregulated space. According to Fuchs, “It is precisely the players who wager the most money and vulnerable groups, such as minors and young adults, who seem to continue to find their way to the illegal supply. That is precisely the group that is most at risk.”

The concern is not limited to consumer safety. Unlicensed gambling providers represent a fundamental risk to the stability and integrity of the regulated gambling system in the Netherlands. They evade licensing fees, avoid taxation, and flout player protection requirements—gaining an unfair competitive advantage over compliant, licensed entities.

Over-regulation may fuel illicit market growth

VNLOK has taken a cautious stance regarding further regulation of the legal market, warning that over-regulation could inadvertently drive more players into the arms of illegal providers. While recognizing the need for effective oversight, the association argues that excessive or overly restrictive policies may have the opposite of the intended effect.

Fuchs elaborated, “If well-intentioned regulation is piled on top of regulation, this will drive more players to the illegal supply. That is where – without any form of supervision or protection – major problems arise.”

This statement underlines the importance of regulatory balance: sufficient to ensure public health and safety, yet not so stringent that it discourages engagement with the legal market. VNLOK advocates for a framework that protects consumers while preserving the attractiveness and accessibility of licensed platforms.

A call for proportional and evidence-based policymaking

VNLOK has urged lawmakers and regulators to adopt a more holistic approach when drafting future gambling policies. According to the association, upcoming legislation should be grounded in evidence drawn from empirical impact assessments such as the one recently published by the KSA. The organization stresses the need to avoid reactionary rule-making that could further destabilize the market.

“Regulation should be effective where necessary but without unnecessarily hindering the player and the legal supply,” said Fuchs. VNLOK also emphasized the importance of involving industry stakeholders in the regulatory process to ensure that proposed measures are both practicable and effective.

Enforcement against illegal providers must be prioritized

In addition to advocating for a balanced regulatory environment, VNLOK is calling for more aggressive enforcement action against illegal operators. The group insists that without stricter oversight and tangible deterrents, the illegal market will continue to grow—undermining the efficacy of every well-intentioned reform introduced on the legal side.

This includes urging the government to strengthen cross-border collaboration with other regulators and digital platforms to combat unlicensed advertising and payment processing. VNLOK suggests that authorities leverage their cooperation with tech companies and financial institutions to block illegal operators from targeting Dutch players.

The role of technology in future-proofing the legal market

VNLOK believes that technological solutions can also play a role in protecting players and reinforcing the integrity of the licensed sector. Tools such as real-time monitoring, AI-based behavioral analysis, and automated alerts for risky play can help licensed operators fulfill their duty of care without overly burdening users with restrictions.

However, such technologies require investment and innovation—which VNLOK argues can only occur in a climate of legal certainty and regulatory stability. If the market becomes over-regulated or uncertain, operators may deprioritize such enhancements in favor of cost-cutting or even consider exiting the jurisdiction.

Striking the right balance is critical for long-term success

The current tension between effective regulation and illegal market expansion poses a significant challenge for Dutch gambling policy. While the new rules introduced in October 2024 appear to be working within the licensed sector, the same cannot be said for the broader market. Unless illegal providers are decisively tackled, the Dutch government risks eroding the very gains it seeks to build upon.

VNLOK’s message is clear: only through a proportionate, evidence-based approach to regulation—coupled with aggressive enforcement against non-compliant entities—can the Netherlands maintain a safe, fair, and functional online gambling market.

Conclusion

The evolving landscape of online gambling in the Netherlands is at a pivotal juncture. While recent regulatory measures have led to meaningful improvements in player protection within the licensed market, they have also unintentionally contributed to the resurgence of illegal gambling activity. VNLOK's position is both pragmatic and urgent: the current trajectory, if left unchecked, risks undermining the very safeguards the new rules were designed to establish.

A measured and balanced regulatory approach—one that supports responsible play without overburdening compliant operators—is essential. Simultaneously, there must be a firm and proactive crackdown on unlicensed providers, whose unchecked growth threatens consumer safety, market fairness, and regulatory credibility.

By incorporating the findings of impact assessments and prioritizing enforcement alongside proportionate regulation, policymakers can ensure a sustainable and secure gambling environment. VNLOK’s call for collaborative, evidence-based action serves as a crucial reminder that the success of regulation depends not only on rules, but on the ability to adapt to the realities of both legal and illegal markets.

FAQ

What is VNLOK?
VNLOK is the trade association representing licensed online gambling operators in the Netherlands, advocating for fair regulation and responsible gambling.

What does the KSA's latest report indicate?
The Dutch Gambling Authority's report shows improved player protection within the legal market and a decline in high-risk gambling behavior.

Why is VNLOK concerned about illegal gambling?
VNLOK warns that illegal gambling sites are attracting vulnerable players and high spenders, undermining regulatory efforts and consumer protections.

What impact did the new regulations have on player behavior?
Since October 2024, fewer players are setting high limits, and the number of accounts losing more than €1,000 has dropped significantly.

Are players switching between legal platforms to avoid limits?
No. The average number of accounts per player remains stable, suggesting players are not trying to bypass restrictions through multiple accounts.

Why is over-regulation seen as risky by VNLOK?
VNLOK believes excessive regulation could push players toward unregulated sites, where there is no consumer protection or oversight.

What kind of enforcement does VNLOK advocate?
VNLOK urges authorities to take strict action against illegal operators, including blocking websites and payment services that enable them.

How can technology support responsible gambling?
Technology such as AI monitoring and real-time alerts can help identify risky behavior and support operators in fulfilling their duty of care.

What is the current size of the illegal gambling market in the Netherlands?
Roughly half of all online gambling spend—€0.50 of every €1—is estimated to occur on illegal platforms, according to KSA data.

What steps does VNLOK want regulators to take next?
VNLOK calls for balanced, evidence-based regulation and aggressive enforcement against illegal sites, while keeping the legal market attractive and safe.