Dutch Online Gambling Licence Renewals: A Comprehensive Guide to the KSA’s First Reissuance

Dutch Online Gambling Licence Renewals: A Comprehensive Guide to the KSA’s First Reissuance

On Thursday, the Dutch Gambling Authority (KSA) reported that eight online gambling licences had been reissued as part of the regulator’s five‑year renewal plan. This milestone marks the first time since the Netherlands launched its legal online gambling market in 2021 that licences have come up for renewal. The reissued licences allow operators to continue legal operations from 1 October 2026 through to 30 September 2031. The final list of successful applicants will also reveal how many operators have chosen to exit the market rather than seek renewal.

Background and Context: The Dutch Online Gambling Market Since 2021

The Netherlands opened its regulated online gambling market in October 2021, granting ten initial licences that were valid for five years. The first cohort of licences is set to expire at the end of September 2026. Under the original framework, all licence holders were required to submit applications for the subsequent five‑year period (2026‑2031). The KSA’s renewal process is therefore a critical moment for the market, testing both the regulator’s new policy approach and the stability of the licensed operator pool.

The Renewal Process: Timeline and First Results

All operators that held a licence from the 2021 round were obliged to apply for renewal. The KSA evaluated applications against updated criteria, including enhanced scrutiny of past compliance behaviour. The eight operators that successfully obtained renewal are:

This list reflects a mix of local operators (e.g., TOTO, Holland Casino) and internationally‑based ones (e.g., Bet365, GG Poker). Notably, no new operators received approval; all reissued licences went to previously active incumbents. Two of the original ten operators – LiveScore and Tombola – exited the market in 2024, before the renewal round began.

Regulatory Evolution: A More Stringent Renewal Framework

Compared to the 2021 licensing round, the KSA adopted a more granular and rigorous approach to licence renewal. This was expected after the regulator published new policy rules in September 2025.

The “Lesson‑Learned” Requirement

One of the most significant new rules relates to operators that had faced compliance enforcement during the first five years of operation in the Netherlands. The KSA stated:

“Providers that made mistakes in the past five years must explain during the application process how they have learned from previous mistakes and how they intend to prevent recurrence. If we find this explanation insufficient, the permit may be denied or additional conditions and restrictions may be imposed.”

This requirement raised concerns among operators who feared that barriers to entry had become overly restrictive. However, at a policy meeting last year, the KSA reassured licensees that it was not enforcing an unreasonably strict standard.

Industry Reaction: Relief and Clarification

Speaking to iGB at the time, Bjorn Fuchs, chairman of the Dutch online gambling association VNLOK, described the industry’s reaction:

“There was a sigh of relief going through the room when it was presented.”

Fuchs explained that the new framework was not a blanket crackdown. Instead, it created a more regulated renewal process. He elaborated:

“If you [as an operator] have a clean sheet, there are some hoops, but for various modules you can just send a declaration which states that you’re compliant.”

He emphasised that the new system would make administrative burdens less demanding than initially feared, though the introduction of an “exit plan” requirement and sharper duty‑of‑care definitions added some complexity.

New Obligations for All Licensees

The renewal process introduced several new obligations that apply to every applicant.

The Exit Plan Requirement

All submissions must now include an exit plan – a new obligation that applies across the board. The purpose of this requirement is to ensure orderly market withdrawal. Operators must describe in detail how they will responsibly wind down their operations if:

This move embeds long‑term risk management directly into the licensing process. An exit plan might cover, for example, how customer funds will be returned, how player accounts will be closed, and how problem gambling support will be maintained during the wind‑down.

Additional Points for Attention

The KSA noted that several operators received “additional points for attention”. This indicates that while these applicants met the minimum legal thresholds, the regulator expects continuous improvements in compliance practices. Operators with such points may face more frequent monitoring or future condition adjustments.

Examples of Compliance Issues: TOTO Online BV

The article highlights one operator that has faced past compliance enforcement. In June 2024, TOTO Online BV was reported for violating the ban on featuring role models in advertising materials. This was not the first time the platform had been in trouble with the KSA. In 2022, TOTO was fined for a similar infringement – gambling advertisements that appeared to be aimed at young people.

Such cases illustrate the type of past mistakes that operators must address in their renewal applications. They need to demonstrate what corrective actions were taken (e.g., removing problematic ads, retraining marketing teams) and how they will prevent recurrence (e.g., implementing stricter content‑approval workflows).

Implications for the Market

The first round of licence renewals signals a maturing regulatory landscape in the Netherlands. The fact that eight of the original ten operators reapplied and succeeded shows a relatively stable market, though LiveScore and Tombola’s earlier exit suggests that not all incumbents found the Dutch market sustainable.

For operators that faced compliance issues, the renewal process provided an opportunity to show improved behaviour. For others with a clean record, the process was smoother, mainly involving declarations of compliance.

The enhanced scrutiny and new obligations – especially the exit plan – may influence how operators think about long‑term investment in the Netherlands. The KSA’s approach balances market continuity with higher standards of accountability.

Conclusion: What This Means for Operators and Players

The KSA’s first online licence renewal round sets a precedent for future renewal cycles. Operators now have a clearer picture of what is expected: robust compliance history, proactive measures to address past mistakes, and a well‑defined exit plan. For players, the renewal process reinforces that the Dutch regulator is committed to maintaining a safe and accountable gambling environment, with licensed operators held to increasingly demanding standards.

As the market moves towards its next five‑year phase, both incumbents and potential new entrants will need to align their operations with the KSA’s evolving framework. The eight reissued licences represent not just continuity, but a stepping stone toward a more disciplined and responsible online gambling sector in the Netherlands.