Key Points
- The KSA’s own calculation wrote the fine up to €292.6 million, which is a pretty big deal until the 10% cap on turnover comes into play and brings it back down by almost 87%.
- EOD Code is still holding out on paying €840,000 of an earlier fine, and won’t even answer the regulator’s requests about the money.
- So, the real test of this case is whether the regulator will actually be able to get their hands on the fine money, rather than just whether it was a record-breaking amount.
The Dutch regulator had determined a fine of €292.6 million for EOD Code SRL, but the law stepped in to prevent that amount from being imposed. Instead, the Netherlands Gambling Authority (KSA) came down on EOD Code with a fine of €37.25 million on 22 October 2026.
The regulator’s own announcement tells the story of a penalty that stood at around €37 million, calling it the highest fine the KSA has imposed so far for an illegal gambling operation, however, reports of the decision have it coming in at exactly €37,250,000.
The 12 Casino Empire Built on Instantcasino
The whole thing started with a single casino brand and a test account. Regulators came round and checked Instantcasino six times between November 2024 and July 2026. What did they do? They registered with Dutch details and put in €20 in Bitcoin. During sign-up, the site automatically suggested “The Netherlands” as a country, and even gave them the +31 dialling code too.
It was in April 2026 that they discovered the full extent of the site. There were eleven other sites run by the same company open to Dutch players. Another ten of them were skyhills.com, slotmonster.com and luckypays.io, a few of them even accepted iDEAL, the super popular Dutch online banking payment method. Dutch influencers gave Skyhills a shout-out on Instagram, YouTube and Discord, and customer support chatted with players in Dutch. Not a single one of those sites said it was one of the countries that were excluded from the site either.
Why did the regulator not act sooner? They already had a penalty in place for Instantcasino. This one threatened a weekly fine of €280,000, up to a maximum of €840,000.
How €292.6 Million Got Knocked Back Down to €37.25 Million?
EOD Code wasn’t exactly courteous to the KSA when they asked for its financial info back on 26 May 2026, and when the regulator invited them to comment on the fine on 10 September, they didn’t even bother to show up. So, without much choice, the regulator had to make an educated guess on the company’s revenue figures using Google Ads for the twelve sites. This is a pretty rough way of doing things, and you can only get an estimate, not properly audited accounts. The KSA reckoned that the Dutch gross gaming revenue for 2025 was closer to €108.4 million.
The regulator’s fine policy starts off with a base fine equal to 100% of revenue, and then they add a bit more on top for aggravating factors. 170% extra points came from the site’s lack of visible age checks, as well as their pretty shoddy terms. There was one term in particular that said the company could keep a player’s remaining balance if they requested to be permanently excluded from the site.
Similar Story with Novatech
KSA levied the then-record fine amount of €24.8 million against Novatech in March 2026. “Without the 10% maximum,” noted KSA chair Michel Groothuizen, “the fine would have exceeded €100m.” Hence, the revenue-based cap rather than KSA’s fine-setting policy determined the record fine.
The EOD Code case offers yet another example of a certain peculiarity. The total fine corresponds to about one-third of the company’s annual revenue from the Dutch market. The proportion of Dutch players in the company’s worldwide clientele amounts to about 29%. The company that relies more on the domestic market thus loses less of its Dutch revenue to the cap.
Let us turn to the case of Gammix to see why it is important to be critical about revenue estimates. In 2024, the KSA imposed a fine of €19.7 million against the company. Gammix claimed the estimate was incorrect and that the fine was excessive. However, in September 2025, the KSA rejected those objections, stating the revenue from the Dutch market for 2022 amounted to €52.4 million. The worldwide revenue of the company was put at close to €1.8 billion, leaving the fine well under the cap. Meanwhile, Gammix still had the opportunity to take the matter to court.
Collection of the Fine
EOD Code has six weeks to pay, which is also the period during which the company can submit an objection. However, that action will not affect the obligation to make payments. Meanwhile, no evidence has been presented that the operator paid the previously ordered €840,000 fine. In his 14 October article, Groothuizen reported that “fines have almost no effect on collection”.
It seems worth raising more questions due to the ownership structure. EOD Code claims it is registered in Costa Rica; however, the jurisdiction over the company’s sites belongs to the courts of Curaçao. In September, Nederlandse Loterij addressed EOD Code’s operators and directors, asking them to stop targeting the Dutch market, as well as to assume responsibility and provide information about the ownership structure. The KSA based its decision on the site being operated without a Dutch licence.
Payment Rails, Ads and AI Chatbots
The Netherlands’ Gaming Authority (KSA) is saying that fines are just one part of the picture when it comes to enforcement. Behind the scenes, they’re working with banks, hosting companies and payment providers to get the job done. This month the head of the KSA said they’re not afraid to take Big Tech to court if things don’t go their way in the talks. And there’s been a breakthrough, a joint task force with Google is working on a list of approved online gambling suppliers across the EU.
It’s easy to see why all of this matters when you look at the numbers. Legal online gambling only launched in the Netherlands in October 2021, and by this spring the KSA’s own report said that 53% of all money going into online gambling was going to licensed operators. That’s up from 49% after a bit of a correction, still a long way to go before all of the problem’s sorted out. In August a TV station called BNR dug up a pretty scary story, it turned out that some illegal operators had found a way to get ads past the self-exclusion register on Facebook and Instagram. The government has announced plans to stop online gambling ads altogether, and make it harder for operators to offer bonuses.
But there’s another problem for the regulator on the horizon, namely the rise of AI chatbots. In August a study came out that tested 10 different AI assistants, all of them, including the popular ones like ChatGPT, named an unlicensed operator at least once. In fact, 33 out of 79 conversations included some kind of recommendation for an illegal site. And get this, four of the tools started spouting recommendations after just a single question. The study only looked at the chatbots’ responses, it didn’t try to work out how they’d actually be used in real life. The test was in Dutch, and it was a relatively small sample size, but the results were still pretty revealing.
Expert Analysis: Is a Record Fine Really a Win?
To be honest, we think the record fine is the least interesting part of the whole thing. When you crunch the numbers, the figures tell a pretty simple story: the KSA’s own estimate of revenue from the illegal operators came out at around €292.6 million, but because of a technicality in the law, the fine in the end was capped. And when you’ve already had a warning and you still refuse to pay up, the fine is just a publicity stunt until the money is actually collected.
The KSA will argue that nailing twelve sites with a big fine still puts pressure on the wider network, and that’s got to be worth something. And they do say that fines are just one tool in their enforcement kit. But on the other hand, if you want to deter people from getting involved in this kind of thing, you need to make sure that the fine is actually going to hurt. And in this case, we’ve still got €840,000 outstanding from an earlier case, which doesn’t exactly fill us with confidence.
The part of the case that’s still a bit dodgy is the estimate of how much cash changed hands. The KSA’s calculation is based on search volumes, but it looks like at least three operators may have been fiddling the numbers. EOD Code, the company that got fined previously, might even challenge the whole calculation method. Whether or not they will is anyone’s guess at this point.
Our hunch is that what really matters here is iDEAL, the Dutch banking system, and the people with big followings online. These are all areas where the real change will be made, and not just a record fine. It’ll be the first euro that lands in the regulator’s lap, or doesn’t land there, that’ll tell us what’s really going on here.
Share
8 views
