Key Points
- One-half of all euros that Dutch citizens bet is going to the black market, costing the Netherlands at least €500 million each year in lost tax revenues.
- The illegal businesses deliberately seek out individuals who are on the Cruks self-exclusion list; there was even a gambling advertisement website which advertised itself as 113.nl, the Dutch suicide prevention service.
- The KSA’s own fines, including its record €24.8 million penalty against Novatech, see little actual payment because operators vanish into Curaçao and Comoros shell structures beyond Dutch legal reach.
Something in the Dutch gambling market’s numbers does not add up, and the country’s chief gambling regulator is no longer willing to gloss over it. In a blog post published on 11 September, KSA chairman Michel Groothuizen put the figure plainly: of every euro Dutch consumers gamble, half goes to the illegal market. That single statistic undercuts the idea of a well-functioning licensed sector and places it next to a shadow market of comparable scale running alongside it, largely unchecked.
The lost tax revenue from that shadow market runs to more than €500 million a year, according to Groothuizen’s own estimate. His blog post came days after the Dutch parliament’s annual gambling committee debate, which he said gave serious attention to illegal gambling but almost none to the cross-border enforcement question he considers most urgent.
The Fine That Rarely Gets Paid
The KSA has not been passive. Its record €24.846 million penalty against Novatech, whose decision was dated 16 December 2025 and publicly announced on 10 March 2026, is the largest fine the regulator has ever issued. Novatech operated the unlicensed websites Qbet.com and 55Bet.com in the Netherlands. The fine stands; the collection is another matter.
“We impose fines running into the tens of millions, but which are, relatively speaking, only a fraction of what they would have had to pay in taxes on their profits if they had been legal,” Groothuizen said. “Moreover, we impose these fines on parties that change their legal guise even faster than they pop up. And even if we know who they are and where they are located, they turn out to have established themselves in the Comoros or in other places where our long arm of the law cannot reach.”
That last point explains why Groothuizen describes fine collection as something that rarely happens in practice. Operators restructure, relocate, and resurface under different identities in jurisdictions the KSA cannot reach. The penalty on paper does not translate into money recovered, and it certainly does not stop the gambling from continuing.
Suicide Prevention Sites, Self-Exclusion Bypass, and a €12 Billion Black Market
The enforcement picture is frustrating enough. The player protection reality is worse. Groothuizen’s blog cited a case where a gambling advertising website presented itself as 113.nl, the Netherlands’ suicide prevention service. Separately, he described how the majority of illegal operators specifically target people registered with Cruks, the national self-exclusion register, with a direct pitch: bypass your gambling block and keep gambling with them.
“These parties not only disregard national laws and regulations but also take no responsibility whatsoever for their players,” Groothuizen said. “The majority of illegal gambling providers actively target people who already have gambling problems and have registered in the Cruks exclusion register. Their message? Bypass Gokstop, keep gambling with us.”
These operators belong to a sector whose global illegal gambling turnover, Groothuizen says, exceeds the GDP of every country except the US and China. A 2025 net-revenue estimate from Euromat-commissioned research covering 28 European markets put Europe’s illegal online gambling market at €12 billion. That figure arrived alongside a September 9 report from the Financial Action Task Force, drawing on data from more than 80 jurisdictions, which found illegal gambling markets rival or exceed legal markets in a number of countries.
Fighting a Global Network With Local Police
Groothuizen’s sharpest line described the structural mismatch at the heart of the problem. “We are fighting a global network of ruthless criminal organisations with dedicated community police officers, whereas we should actually be deploying an international investigative service.”
The KSA’s practical efforts to shift that balance have been real. A 2024 agreement with Cloudflare gave the regulator the ability to request hosting information behind illegal gambling sites. The KSA also took enforcement action against prediction market platform Polymarket, whose operator forfeited a €420,000 penalty after breaching an enforcement order for operating without a licence. Dutch state lottery Nederlandse Loterij has filed legal actions against multiple offshore operators, including Skyhills.
Each of these actions addresses symptoms. Groothuizen’s argument is about the underlying structural problem: the companies the KSA most needs to co-operate with, major tech platforms and global payment providers, are not Dutch entities and operate at a scale that makes national pressure largely ineffective. “Compared with these globally operating technology and financial companies, the Netherlands is far too small,” he wrote. “Inevitably, we need Europe to persuade such companies to work with us in the fight against illegal gambling.”
Parliament Debated Broadly but Missed the Central Point
Dutch lawmakers covered considerable ground at their annual gambling debate: raising the minimum gambling age to 21, capping the number of licence holders, a potential advertising ban, a central login portal for licensed operators, and whether investigators could use false identities in operations against illegal gambling. State Secretary Claudia van Bruggen indicated she is examining whether maximum fines are high enough and looking into a ban on gambling with borrowed money. DNS blocking legislation is being planned for consultation in early 2027, though van Bruggen acknowledged that timetable is ambitious.
What received almost no attention was cross-border enforcement capacity. Groothuizen flagged this directly, warning that a parliament that treats international capacity as an afterthought will produce a state department that does the same. “Illegal operators have long operated across borders,” he said. “Their entire habitat is international, from money flows to advertisements on social media. Making a real impact requires the capacity to act at European level. That understanding does not yet appear to be widespread in the Dutch House of Representatives.”
This is not the first time the KSA’s resource constraints have been formally noted. A 2022 government evaluation found that implementing the Remote Gambling Act had absorbed KSA capacity in ways that constrained the regulator’s ability to strengthen online enforcement, with licensed market participants reporting that illegal supply still received insufficient attention. Four years later, the chairman is making the same argument, this time at a continental level.
Expert Analysis
We think the most revealing line in Groothuizen’s blog is not the €500 million figure or the Comoros reference. It is his observation that the KSA’s fines are, in his own words, “only a fraction” of what operators would have paid in taxes had they been legal. That exposes something regulators rarely say publicly: the penalty structure is not deterring the behaviour it is supposed to stop. For an illegal operator running at scale, a fine that rarely gets collected is not a cost; it is a theoretical number that changes nothing.
That FATF released the report of September 9 prior to this statement was not accidental as far as the relevance is concerned. FATF found that in around 80 jurisdictions, illegal gambling industries compete with or surpass legal gambling in many nations. It also identified the very same structure-related problem as Groothuizen does – the money flows, company structures, and advertising channels that operate in all countries where any national regulation ends. What we find disconcerting in the discussion within the Dutch parliament on this issue is not the difference in opinions regarding advertising prohibitions and age restrictions; it is a natural thing for any two different people to have opposing views on the matter. What makes us uncomfortable about this discussion is the fact that a whole hall of lawmakers considered the symptoms of the problem extensively but paid little attention to its cause.
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