A joint study by XY Legal Solutions BV and VNLOK has exposed the staggering scale of unlicensed online gambling advertising in the Netherlands, finding that illegal operators reached Dutch consumers millions of times through digital channels. The research, which examined advertising activity across social media platforms and search engines, paints a troubling picture for regulators already under pressure to enforce the country’s regulated gambling framework. At a time when the Kansspelautoriteit (KSA) faces scrutiny over enforcement gaps, these findings add fresh urgency to the debate over how effectively the Dutch market is being policed.
What the Research Actually Found
The study tracked advertising impressions served by unlicensed gambling operators targeting Dutch-speaking audiences. According to the findings, these ads appeared across major platforms including Google, social media networks, and affiliate websites, collectively generating millions of impressions. The operators behind these campaigns hold no licence from the KSA, meaning every impression represents a potential violation of the Netherlands’ Remote Gambling Act (Wet kansspelen op afstand, or Koa), which came into force in October 2021.
What makes this particularly striking is the apparent ease with which unlicensed brands circumvented platform-level ad restrictions. Despite Google and Meta both maintaining policies that require gambling advertisers to hold valid local licences, the research suggests enforcement of those policies remains inconsistent (a distinction regulators have been slow to enforce). Several operators used redirecting domains, localised landing pages, and affiliate intermediaries to place ads that would otherwise be blocked.
Scale of Unlicensed Gambling Promotion in the Dutch Market
Before examining the strategic implications, it helps to understand the raw dimensions of the problem uncovered by this research.
- Millions of ad impressions from unlicensed gambling operators were served to Dutch users across digital platforms
- Multiple unlicensed brands ran concurrent campaigns, some sustained over weeks rather than isolated bursts
- Affiliate networks played a central role in distributing ads on behalf of operators without KSA authorisation
- Platform-level compliance checks failed to catch a significant portion of these campaigns before they went live
- The research was conducted by the Dutch trade association for licensed online gambling operators, VNLOK, alongside legal consultancy XY Legal Solutions BV
Why Platform Enforcement Keeps Falling Short
Google, Meta, and other major ad platforms have built compliance frameworks designed to verify advertiser credentials before gambling-related campaigns go live. In practice, these systems rely heavily on self-declaration and automated checks that can be gamed. Unlicensed operators exploit this by registering ads under non-gambling categories, using intermediary domains that redirect to gambling sites only after the ad click, or running campaigns through affiliate accounts that are not flagged as gambling-related.
The gap between policy and execution is not new. But the Dutch data gives it a number.
And while platforms have invested in machine learning tools to detect policy violations at scale, the cat-and-mouse dynamic favours operators willing to burn through disposable domains and ad accounts. For every campaign that gets flagged and removed, another can launch within hours using a fresh set of credentials. The cost of non-compliance, at least on paper, remains lower than the revenue these ads generate.
A Regulatory Bottleneck
The KSA has issued fines and warnings to unlicensed operators in the past, but cross-border enforcement remains a persistent challenge. Many of the operators identified in the study are domiciled outside the EU, making direct regulatory action slow and often ineffective. Whether the KSA will shift its enforcement posture toward the platforms themselves, rather than solely targeting operators, is a question the industry is watching closely.
How This Shapes the Licensed Market
For operators holding valid KSA licences, the proliferation of unlicensed advertising creates an uneven playing field. Licensed operators are bound by strict advertising codes, including limitations on targeting, messaging, and the use of role models. Unlicensed competitors face none of these constraints, allowing them to deploy aggressive acquisition tactics that licensed brands cannot match.
| Factor | Licensed Operators | Unlicensed Operators |
|---|---|---|
| Advertising restrictions | Subject to KSA advertising code and Dutch Advertising Code | No compliance obligations observed |
| Targeting limitations | Cannot target vulnerable groups or minors | No verified age-gating or exclusion protocols |
| Platform verification | Must submit licence credentials to ad platforms | Bypass verification through affiliates or mislabelled campaigns |
| Enforcement exposure | Directly accountable to KSA | Often domiciled outside EU jurisdiction, limiting enforcement reach |
This asymmetry arguably undermines the entire rationale of the Dutch licensing regime, which was designed to channel demand toward regulated, consumer-protected offerings.
The Broader Signal for European Regulators
The Netherlands is not alone in grappling with unlicensed gambling advertising. Similar patterns have been documented in Germany, Italy, and Belgium, where regulated markets coexist with persistent grey-market activity. Still, the Dutch case is instructive because the Koa framework was built with digital enforcement in mind. If even a purpose-built regulatory architecture cannot prevent millions of unlicensed ad impressions from reaching consumers, the question extends well beyond one national regulator’s capacity.
Some industry voices have called for a coordinated EU-level response, potentially involving mandatory ad verification standards for platforms operating across member states. The Digital Services Act (DSA) provides a partial framework, but its provisions on advertising transparency were not specifically designed with gambling in mind. That gap matters, because gambling advertising sits at the intersection of consumer protection, addiction prevention, and market integrity in ways that generic ad transparency rules do not fully address.
Frequently Asked Questions
What is the KSA?
The Kansspelautoriteit is the Dutch gambling authority responsible for licensing and supervising all legal gambling activity in the Netherlands, including online operations authorised under the Remote Gambling Act.
Are these ads actually reaching minors?
The research did not isolate minor-specific exposure data, but the absence of age-gating on unlicensed campaigns means there are no verified safeguards preventing it. Licensed operators, by contrast, must implement targeting restrictions that exclude users under 24 from certain ad formats.
Can the KSA fine platforms directly?
Under current Dutch law, the KSA’s primary enforcement tools target operators and affiliates rather than ad platforms. Whether this changes may depend on how the DSA’s advertising provisions are interpreted and enforced at the national level.
Why do unlicensed operators target the Dutch market specifically?
The Netherlands has a relatively affluent, digitally connected population with high online gambling participation rates. These characteristics make it commercially attractive, even for operators unwilling to bear the compliance costs of a KSA licence.
