(AsiaGameHub) – Vergunde Nederlandse Online Kansspelaanbieders (VNLOK) is urging Dutch policymakers to develop a more precise understanding of the illicit gambling sector and to combat it with greater vigor.
This appeal from the industry association follows the release of the spring 2026 monitoring report (H2 2025) by the Dutch gaming regulator, Kansspelautoriteit (KSA). The report indicates that while growth in the regulated online gambling sector has leveled off, the black market is expanding.
Metrics regarding the volume of licensed operators, gross gaming revenue (GGR), player counts, and channelization rates remain largely consistent with the previous autumn report (H1), though there has been a rise in the total number of active player accounts.
KSA Chair Michel Groothuizen emphasized that there will be no easing of duty-of-care requirements for licensed operators, as the regulator and the industry must prioritize the protection of young adults (aged 18–24) from gambling-related harm.
Duty of care was identified as one of five primary focus areas in the regulator’s 2026 supervisory agenda, alongside combating illegal operators, safeguarding vulnerable demographics, overseeing advertising practices, and ensuring compliance with the Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft).
Dutch market in H2 2025
Total GGR for the second half of 2025 reached €602m, a slight increase from the €600m recorded in H1, averaging roughly €100m per month—a decline of approximately 18% compared to 2024 levels.
KSA estimates suggest that about 500,000 individuals gambled monthly during H2. While roughly 91% of players utilized only licensed operators, the financial channelization rate was lower, at 53%.
The KSA noted that this figure is higher than the 49% estimate from the previous report due to a data correction, and attributed the overall decline to several contributing factors.
The regulator believes that player protection initiatives, such as the net deposit limits implemented in October 2024, are proving effective, as average monthly player losses have trended downward since 2024.
However, in H2, average losses rose to €124 per month, up from €117 in H1. This metric accounts for individuals who use multiple platforms and those who are not active every month.
Young adults (18–24) accounted for 22% of accounts used in H2, though they incurred lower monthly losses—averaging €34 compared to €73 for older adults—and showed a preference for sports betting.
VNLOK – proportional regulation focus
VNLOK observed that while the licensed market is becoming increasingly secure, it is also facing mounting pressure, warning that further restrictions on legal operators could drive more consumers toward the black market.
Consequently, the trade body is advocating for a focus on “proportional regulation, robust enforcement against illegal operators, and improved monitoring of overall gambling patterns.”
Björn Fuchs, Chair of VNLOK, remarked: “This report demonstrates that the legal market is providing better protection for players. Simultaneously, however, we see the legal sector contracting significantly, with tens of thousands of players participating in the illegal market each month, where they collectively lose an average of €100m monthly.”
“This is deeply concerning. Now more than ever, it is vital to look beyond the legal market, gain a clearer understanding of the true scale of the illegal sector, and intensify efforts to address it.”
VNLOK stated that the Dutch legal online gambling market has shrunk by nearly 20% since 2024, with player numbers also trending downward throughout 2025.
The association believes the scale of the illegal market is currently underestimated and is calling for the development of “a more reliable and robust methodology to accurately map the total number of players, both legal and illegal,” citing the risk that policy decisions may be based on an incomplete understanding of where players are active.
“Now more than ever, it is important not only to look at the legal offering, but to gain a much clearer picture of the true size of the illegal market and to intensify the approach to tackling it.”
Björn Fuchs, Chair of VNLOK
Groothuizen – Duty of care a top priority
In a blog post, Groothuizen attributed the stagnation of the Dutch regulated market to the 2024 introduction of deposit limits and last year’s increase in gambling taxes.
Groothuizen acknowledged that the illegal market is expanding due to technological advancements like AI and cryptocurrency, as well as the fact that deposit limits and financial vetting are prompting players to open multiple legal accounts or migrate to unlicensed operators.
While the introduction of a universal gambling limit to prevent players from switching between licensed operators is a potential market change, the KSA Chair noted that this would not deter players from using illegal sites. Nevertheless, he remains optimistic.
Groothuizen stated: “Fortunately, many Dutch citizens appear to value legal gambling, so the number of those switching may be lower than anticipated. This will undoubtedly depend on the threshold of such a limit.”
“It also means we must ensure the legal market remains visible to players—meaning no total advertising ban—while simultaneously ensuring the illegal market is addressed more effectively.”
“We must keep the legal offering visible to players (so no total ban on advertising), but also that, on the other hand, the illegal market must be tackled more effectively.”
Michel Groothuizen, Chair of Kansspelautoriteit
The KSA chair added that he remains firmly opposed to relaxing duty-of-care standards for licensed operators, as the regulator must do everything possible to protect young adults gambling online.
“While most Dutch players gamble for recreation and maintain self-control, we, as the Gaming Authority, must not gamble with the safety of those who may have lost control of their behavior. Young people, whose brains are still developing and who are prone to impulsivity, are a particular cause for concern.”
“Strict adherence to the duty of care remains a top priority for the legal market. It goes without saying that the illegal sector has no regard for the harm that gambling can cause.”
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