Key Points
- 8 operators received their licences for online gambling in the Netherlands for the period from 1 October 2026 to 30 September 2031.
- New BRVKOA 2026 rules require all expiring-licence applicants to submit an exit plan and account for definitively established compliance violations from the preceding five years.
- TOTO Online collected three separate KSA enforcement actions between 2022 and 2026, yet received a renewal, as the illegal market now accounts for more GGR than licensed operators.
The Dutch Gambling Authority (KSA) confirmed on 17 September 2026 that eight online gambling operators had received follow-on licences covering the period from 1 October 2026 through 30 September 2031. Five years after the Dutch regulated market opened, this is its first meaningful test of who actually belongs in it. What came out of that test is revealing, though not always in the way the headlines suggest.
The eight licensees include TOTO Online BV (TOTO, Winnitt), Holland Casino NV (Holland Casino Online), Play North Limited (Kansino), FPO Nederland BV (FairPlay Casino), Bingoal Nederland BV (Bingoal), Hillside (New Media Malta) Plc (Bet365), NSUS Malta Limited (GGPoker), and Betent BV (Betcity). All eight companies in the above-mentioned list are also members of the initial 2021 licensing round. So far, no new licensee has been issued.
Ten Became Eight Before a Single Renewal Was Issued
The original 2021 licensing round brought in ten operators. By 2024, two had already left. LiveScore and Tombola both exited the Dutch market that year, before any renewal decision had been made. The KSA has not publicly explained their departures. The result is that the “first eight renewals” are partly a story of who stayed, not just who passed scrutiny.
Those operators whose original five-year licences were expiring in 2026 were required to apply for follow-on licences, since an existing licence cannot simply be extended. The distinction matters: this was not an automatic rollover for every Dutch gambling licence holder. It applied specifically to the cohort whose permits were reaching the end of their first term.
What the New Framework Actually Required?
The process of renewal was regulated by the BRVKOA 2026, the new set of regulations for licensing policies which became effective from 1 January 2026. Two modifications to the 2021 regulation framework were introduced.
The first is the exit plan requirement, which now applies to every applicant. Operators must describe in detail how they would wind down operations if their licence expired early, was revoked, or if they chose to leave the market between renewal cycles. The KSA’s framing is explicitly about player protection: it cannot be predicted whether, when, or under what circumstances a licence will end early. Handling player balances, customer communication, technical shutdown procedures and data retention compliance all have to be mapped out in the application, not after a crisis.
The second change concerns past violations. 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.” The wording refers specifically to definitively established violations; applicants were required to detail corrective measures taken and outline steps to prevent future breaches.
The Room Exhaled, but the Complexity Remained
When the KSA presented the renewal framework to operators at its Den Haag headquarters in October 2025, the reaction was notably one of relief. Bjorn Fuchs, chairman of VNLOK, the Dutch iGaming trade body, recalled that “there was a sigh of relief going through the room when it was presented.” Operators had entered that room fearing a hard reset.
Fuchs summarised what emerged: “If you have a clean sheet, there are some hoops, but for various modules you can just send a declaration which states that you’re compliant.” Clean-sheet operators faced process, not crisis. Those carrying compliance baggage faced a more uncomfortable conversation with the regulator.
The KSA noted that several applicants received “additional points for attention,” meaning they met minimum legal thresholds but the regulator expected continuous improvement in compliance practices. That phrase deserves more attention than it has received. It is not a clean pass.
TOTO’s Renewal Comes After Three KSA Enforcement Actions
Among the eight renewed operators, TOTO Online’s position is the one that most invites scrutiny. The operator accumulated three separate KSA enforcement actions across the five-year licensing period.
The first was a €400,000 fine issued in November 2022. The KSA found that TOTO had sent advertising messages to its entire customer base, which included players aged 18 to 23, a group specifically protected under Dutch law. KSA chairman René Jansen stated at the time: “The law says that vulnerable groups, including young adults, must be given extra protection. Gaming providers must fully respect the rules intended to protect vulnerable groups. That did not happen here and that is why there is a fine.”
The second came in October 2025, when the KSA issued TOTO Online a Wwft enforcement instruction for anti-money laundering violations. The regulator found TOTO had “failed to comply with the ongoing monitoring of business relationships and their transactions” and that its investigations into player fund origins were inadequate. TOTO was given six months to resolve the outstanding violations, with a re-inspection to follow.
The third came in June 2026, when the KSA called out TOTO for violating the national ban on using role models in gambling advertising. The operator had run a promotion through eight professional football clubs, offering a signed shirt to anyone who placed a €5 bet. The KSA’s position was direct: “It was precisely the involvement of these players that made the campaign attractive to supporters. Consequently, the teams were indirectly used to promote online gambling, and the ban on role models was violated.”
Three actions. One renewal. The KSA’s framework allows for this outcome, provided the operator demonstrates sufficient learning and corrective action. What TOTO’s compliance file showed to justify that decision remains private.
Expert Analysis: A Licence List Issued into a Market Under Real Pressure
We have followed the Dutch market since its 2021 launch, and these renewals land at an uncomfortable moment. The regulatory framework is tightening on paper while the legal market is losing ground in practice.
KSA data published in April 2026 revealed that revenue channelisation had fallen to 49% in the first half of 2025, below 50% for the first time since regulation began. The illegal market overtook the licensed sector in GGR terms during that period. The same report showed player channelisation at around 91%, meaning a relatively small group of high-spending players is responsible for a disproportionate share of the money flowing offshore.
Running alongside that trend is a tax framework that has delivered far less than planned. A joint report from the Ministry of Finance and the KSA found that gambling tax receipts in 2025 came in at approximately €2 million above 2024 levels, against a government target of €108 million in additional revenue for that year. The tax rate rose to 34.2% of GGR in January 2025 and increased further to 37.8% in January 2026.
Holland Casino CEO Petra de Ruiter, speaking after her operator’s own renewal was confirmed in August, put the tension plainly: “It remains essential that the regulated market is attractive enough to keep players away from unregulated providers, where supervision and protection are lacking.”
We think she is identifying a contradiction that the KSA has not yet resolved. Advertising restrictions, deposit limits, and rising tax rates are reducing the commercial appeal of legal operators while the regulator is raising compliance standards for renewal. Those two directions are pulling against each other. The eight operators renewed for 2026 to 2031 will be operating in a market where the illegal competition is, by the KSA’s own numbers, already winning on revenue. Whether tighter licences make that better or worse is the question the next five years will answer.
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