Voorzitter Michel Groothuizen gaf dinsdag 21 oktober 2025 een speech op IAGR2025. Lees hieronder zijn Engelstalige speech.
Good afternoon everybody,
Let me share a problem I was confronted with. As a regulator, I am not allowed to take part in any kind of gambling in the Netherlands. Unfortunately, sometimes you happen to participate in a lottery without realising it. This happened to me on my trip to Toronto. Due to technical problems KLM had changed a Boeing for an Airbus. So far so good, but Airbuses are a bit smaller and (at least with KLM) have less business class seats available. Consequently KLM had honestly (as they assured me) drawn a few unlucky ones for an involuntary downgrade. I was one of them. And I confess, I cursed. And realised reluctantly that gambling was not my cup of tea. Better to supervise a market, than to play and lose. In the end, the flight wasn’t bad at all, but still… Maybe you recognise this, and we share this characteristic as regulators.
That is why it is so nice to see you here.
Meetings like these always boost (apart from the jetlag) my energy: on the one hand because the cooperation between regulators ensures that our organisations continue to become ever more professional, and on the other hand because I see that we share many of the same challenges. It is in the context of the latter that you have come here today, of course: to hear what I can share about the challenges facing the gambling market in the Netherlands, what we have learned since the legalisation of online gambling in 2021 and where steps still need to be taken. I’ll walk you through that. I hope that with this presentation you will get some kind of mini in-depth case study of the situation in a pretty small country across the ocean. I am sure that a lot of the dilemmas we were confronted with in the Netherlands and the choices that were made will be recognisable and of interest for many of you.
I will begin with a brief look back on the process leading up to legalisation, give you a brief summary of the first years after opening up the online market and conclude with the challenges for the future, urging you in particular to take up the gauntlet together.
First, let’s look back for a moment.
The political decision-making process surrounding the opening up of the Dutch online gambling market took a lot of effort and, moreover, a very long time. The total legislative process lasted for about two decades. It started around 2000. In 2018, three years before actual legalisation, the proposed bill was still under discussion in the Dutch Senate. It was not until spring 2019 that we got the green light to set up the process: drafting policy rules for granting licences, setting-up and expanding our central data vault and the establishment of a gambling addiction exclusion register. At that time I was employed elsewhere, but I understand from my colleagues that the period before the law was in force was incredibly intense.
Our organisation doubled in no time to a team of circa 100 collaborators, all getting through mountains of work. Since the opening of the market in 2021 we doubled our staff once more to more than 200 these days.
And why were we actually doing that?
An answer to this question can be found in the explanatory notes to the law. First of all, Dutch government wanted to counter illegal providers. After all, the borderless nature of the internet, the ongoing demand of Dutch consumers for online gambling and rapid technological developments, among other things, meant that comprehensive enforcement was impossible without a responsible, reliable and auditable legal alternative.
Addiction prevention was another important reason: preventing high-risk players from developing into problem players requires a licensing system that provides safeguards to protect against the risks of addiction.
Most of the texts that were adopted in the law had already been written in 2013 and before, but honestly the continued and ever faster advances in digitalisation and the widespread and permanent use of mobile devices, in particular smartphones, by almost everyone in the world were not foreseen and the toolbox made available for the authority was therefore, in hindsight, rather limited. These objectives (addiction prevention and countering the illegal market) are just as relevant in 2025 as they were back then. But the incredible worldwide rise of smartphones and the incredulously fast growth of technology have made it harder to reach our goals, instead of easier. These lines may have felt modern at the time; right now it feels like we’re battling a 21th century war with medieval tech.
Opening up such an online market entails a whole slew of political choices which regulators have an opinion on, but unfortunately cannot help decide on.
In the context of one of the main reasons for opening up the market, tackling illegal providers, we failed on a very important point. In order to protect the freedom of the internet, the foreseen power to take down illegal websites our in earlier documents, was scrapped. While I absolutely understand that from the perspective of the open internet and countering government censorship, that amendment in the bill still causes us major problems. I realise from colleagues who have further going powers that even this is not a silver bullet. Nevertheless, we try to tackle illegal websites in a myriad of ways, but the fact that we cannot immediately render them unavailable to Dutch players puts us at an automatic disadvantage in the battle with a very innovative and agile opponent. I will certainly come back to this in a moment when I talk about the focal points for the future.
In the context of the second reason for opening up the market — player protection — political decisions were made at the time, some of which, as regulators, we had reservations about. Especially in the field of advertising, very open standards were applied.
This is understandable, because you are quickly setting up a commercial market and you want to make it attractive for companies to enter that market. They can only do that if they know how to attract players and create a presence for themselves. But we made an important observation: in a market with so much potential and so much money involved, you can bet that parties will push the boundaries of what is permissible. We warned Government for a tsunami of advertising, and were proved, regrettably, absolutely right. From October 2021 onwards, there was no escaping the advertising by gambling companies. It was everywhere, from bus shelters to commercial breaks on television. And of course online.
Pretty our soon politicians regretted their belief in open standards, but it was too late. In a fierce competitive market you may not expect operators to act beyond their own short term survival and maximal profit seeking.
Consequently that flood of advertising led to a huge influx of new players. This is not necessarily a bad thing, as long as legal providers correctly observe their duty of care and employ proper protection to ensure that these players continue to gamble recreationally, without developing problem behaviour. Because we as Ksa could not guarantee that the really open standards in advertising came to an end relatively quickly. In the last few years the responsible minister was increasingly making the rules stricter. First, a role model ban came into force: online gambling companies were no longer allowed to affiliate themselves with well-known figures, to better protect vulnerable young adults in particular. While that ban was certainly effective for young players, the volume of advertising still remained immense.
A ban on untargeted advertising came into force in 2023, a little less than two years after the market was opened up. More and more we moved away from advertising on radio and television, in public spaces and in sports. Online advertising is still allowed, but under strict conditions. Conditions that are not felt by the illegal operators, I regret to say.
One might wonder if we might be better off with a total ban on advertising.
I know that many of you wrestle with that same question, and our Dutch politicians are increasingly calling for that. Still, I do not believe in such a total ban, especially as I look at the recent development of the market. Although our player channelisation rate has remained over 90%, during the first half of 2025 we saw GGR-based channelisation fall slightly below 50% for the first time. This means that roughly half the money involved in gambling in the Netherlands goes to illegal operators.
It is the illegal market that benefits from the stricter measures we impose on the legal market.
This doesn’t only have to do with advertising, but also with the stricter measures we have taken in terms of player protection. The minister responsible for gambling presented a renewed vision on the gambling market earlier this year. This vision is in line with the changing, more negative view on gambling that we are also increasingly seeing in society. Whereas gambling was first seen as a mainly recreational game with occasional negative consequences, government now increasingly regards gambling, and in particular online, as a high-risk product. The minister therefore called his new vision a "fundamental change of direction".
The main premise here is to protect all citizens from the risks of the negative effects of gambling, such as addiction or debt. This includes an extra focus on minors and young adults. This change of direction is largely driven by the idea that current policies thusfar do not protect people adequately.
Requested by government we, as the Ksa, have also further strengthened our guidelines on player protection. With the introduction of a financial deposit limit (of € 700 a month per operator), a big step was taken to prevent players from incurring large losses. When depositing a certain amount, a player must show that he can afford it before he can continue playing. Since the introduction of these measures, we have seen a huge drop in the percentage of players suffering large losses. This does have a direct impact on the GGR of legal providers, and thus also contributed to the declining channelling in terms of GGR.
This heightened focus on player protection and the curtailment of open standards therefore creates tension in our licensed market with circa 30 operators. In the run-up to licence renewal (our first issued licences had a term of five years), I am curious to know which parties will decide to stay and invest further in the Dutch market, and which parties may abandon it. A healthy licensed market hinges on a sufficiently diverse and attractive offering of gambling websites. However, this does not mean that I intend to keep everyone on board at all costs. When we recently published our new policy rules for the second round of licensing, we as the Ksa very actively expressed that we would be taking supervisory antecedents into account in the assessment. Those who have not conducted themselves in line with the standards we like to see as a regulator over the past five years will have to have a good explanation as to why that happened and especially how they will prevent that from happening in the future.
Of course, this turnaround in money channelisation (as said an overwhelming big majority of Dutch players still visits exclusively legal operators) is not only the result of tightening measures. We see globally that the illegal market is on a meteoric rise, seeming to know fewer and fewer boundaries, both geographically and ethically.
Illegal gambling operators are infiltrating forgotten Dutch domains with high SEO scores to reach Dutch players. The domain names of bankrupt restaurants, coaches' websites and even primary and secondary schools are being bought up to set up SEO pages about illegal gambling.
Influencers are being used to log onto illegal casinos and promote gambling in livestreams, with thousands of euros being spent in some cases. Vulnerable young people are being sucked into the illegal circuit left, right and centre.
At the first Player Protection Conference we organised in September in The Hague, it became clear that these innovative tactics of illegal providers are obviously not unique to the Netherlands and that we are facing the same challenges worldwide. While some of you do have the authority to immediately take websites down, we also see new parties popping up quite quickly to cheerfully take over under a slightly different domain name. We therefore had to adjust our wishful expectation that the solution laid in our own enforcement. Thusfar, also mutual cooperation in this respect has not been very fruitful. Though I would like to point out that the constant exchange of information among us about illegal parties can be an enormous help in tackling illegal providers.
Let us put our efforts mainly into a sort of gambling Interpol; first Europe-wide, but then perhaps worldwide.
But, if this direct approach to illegal providers is not the answer, what is?
I won't pretend to have all the answers, because this is a growing and constantly evolving problem that sometimes feels like a Hydra: when we cut off one head, two new ones grow to take its place. We must therefore engage with parties who enable the growth of the illegal market. With this I am referring first of all to big tech and 'big finance'; the social media platforms that enable the visibility of illegal businesses, and the banks and payment service providers that then enable actual payments to be made. Those who do not know that an illegal website exists are not likely to visit it. And those who do unexpectedly find themselves on such a website will quickly leave if there is no possibility of actually placing a bet because you cannot deposit money.
By ‘engage with', I of course mean first and foremost that we as international regulators must join forces. Together enter a dialogue with these parties to see how we can work in coalition to deal with this seemingly endless battle. However, we must also not be afraid to stir things up and act against these parties ourselves, however much we need them. If we do not encounter enough cooperation, we in Europe must urge our EU institutions to push for European minimum standards. We see this happening now in the area of AML. That is an inspiring example, and as far as I am concerned, something we could learn from and act upon in the gambling market as well.
There is a lot for us to learn from each other, so it is good that we as international regulators are in constant dialogue. Only by continuing to learn from each other and looking at the challenges at play in different markets can we grow in our supervision. Moreover, because our markets are international and the internet effectively knows no borders, it is increasingly important that we stand together. That means, on the one hand, harmonised standards in advertising, player protection and addiction prevention (at least up to a certain level) so that we optimally protect all players and do justice to the goal of maintaining a licensed market.
It also means, however, that we will have to cooperate much more extensively in tackling the illegal market, and stand up to the parties around the gambling companies that enable this illegal market to flourish. One might wonder who ultimately bears the final responsibility there: the regulators, the politicians, or the big companies in tech and finance that help keep the market running. But the fact that there is no unequivocal answer to that question does not mean we can absolve ourselves from our responsibility.
Let us all act as if we are the issue owner here, and by doing so let us inspire and include other parties in an ecosystem of experts that is ultimately capable of promoting a healthy licensed market and dealing a real blow to the increasingly brutal illegal market.
This is something I am very keen to discuss with all of you in the coming days.
Thank you for your attention.