Vergunde Nederlandse Online Kansspelaanbieders (VNLOK) is calling on policymakers in the Netherlands to gain a clearer picture of the illegal market and tackle it with increased intensity.
The call from the trade body follows the publication of the spring 2026 monitoring report (H2 2025) from the Dutch gaming authority Kansspelautoriteit (KSA), which revealed that while the legal online gambling market’s growth has stagnated, the black market’s size is increasing.
Figures regarding the number of license holders, gross gaming result (GGR), the number of players, and player channelling remain virtually unchanged compared to last autumn’s report (H1), but there has been an increase in the number of player accounts.
KSA Chair Michel Groothuizen noted that there will be no relaxation on duty of care measures for regulated operators, as the authority and the market must keep it a top priority to protect young adults (18-24 year olds) from gambling harm.
Duty of care was named as one of the five key themes for the gaming authority as part of its supervisory agenda for 2026 at the beginning of the year: tackling illegal gambling operators, protecting vulnerable groups, supervising duty of care, supervising advertising and supervising compliance with Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft).
Dutch market in H2 2025
Overall GGR for H2 2025 came in at €602m, up from €600m in H1, approximately €100m per month and down by around 18% in comparison to 2024 figures.
Approximately 500,000 people played per month in H2 according to KSA estimates. Approximately 91% of gamblers played exclusively with legal providers, but channelisation in terms of money is lower at 53%.
However, the KSA noted that ‘due to a correction of the figures from the previous report, it is higher than the estimate in the previous report, which came in at 49%’ and that the decline is due to several factors.
The authority believes player protection measures that have been introduced, such as net deposit limits in October 2024, are making an impact, as average player losses per month have declined since 2024.
However, in H2, the figure rose to €124 per month compared to €117 per month in H1. This figure also accounts for players playing with multiple providers and not being active every month.
Of the accounts used in H2, 22% were young adults (18-24 year olds), but they lost less per month than their adult counterparts – €34 per month compared to €73 per month for adults – and favoured sports bets as well.
VNLOK – proportional regulation focus
VNLOK noted the figures show the licensed market is ‘becoming increasingly safer’ but is also ‘under increasing pressure’ and thus further restrictions on regulated operators could see more players turn to the illegal market.
As a result, the gambling trade body is asking for more ‘focus on proportional regulation, firm enforcement against illegal providers and better monitoring of overall gambling behaviour’.
Björn Fuchs, Chair of VNLOK, stated: “This monitoring report shows that the legal offering protects players increasingly better. But at the same time, we see that the legal market is shrinking significantly and that tens of thousands of players are also gambling illegally every month, where they collectively lose an average of €100m per month.
“That is extremely worrying. Now more than ever, it is important not only to look at the legal offering, but to gain a much clearer picture of the true size of the illegal market and to intensify the approach to tackling it.”
VNLOK said that the Dutch legal online gambling market has declined in size by almost 20% since 2024, with the number of players showing a downward trend in 2025, too.
It also believes the illegal market’s size is being underestimated and thus is calling for ‘a more reliable and robust method to better map the total number of players, both legal and illegal’ to be developed, as there is ‘a risk that policy will be based on an incomplete picture of where players actually end up’.
“Now more than ever, it is important not only to look at the legal offering, but to gain a much clearer picture of the true size of the illegal market and to intensify the approach to tackling it.”
Björn Fuchs, Chair of VNLOK
Groothuizen – Duty of care a top priority
In a blog post, Groothuizen stated that the regulated market in the Netherlands has stagnated because of the introduction of deposit limits in 2024 and an increase in gambling tax last year.
Groothuizen also acknowledged that the illegal market is growing due to technological developments such as AI and cryptocurrency gambling, as well as deposit limits and financial checks, causing players to open multiple legal accounts or move to illegal operators.
One potential change to the Dutch market could be the introduction of an overarching gambling limit to stop customers from hopping between regulated operators. However, the KSA Chair pointed out that this would not stop players from playing on illegal websites, but he has optimism.
Groothuzen said: “Fortunately, a great many Dutch people seem to value legal gambling, so perhaps the number of switchers will be lower than expected. This will undoubtedly also depend on the level of such an overarching limit.
“It also means that we must keep the legal offering visible to players (so no total ban on advertising), but also that, on the other hand, the illegal market must be tackled more effectively.”
“We must keep the legal offering visible to players (so no total ban on advertising), but also that, on the other hand, the illegal market must be tackled more effectively.”
Michel Groothuizen, Chair of Kansspelautoriteit
The KSA chair added that he is firmly against relaxing any duty of care measures for regulated operators, as it must do everything it can to protect young adults who gamble online.
“Although the majority of Dutch players still gamble for fun and have self-control, we, as the Gaming Authority, certainly should not take a gamble with people who may no longer have their gambling behaviour under control. And it is certainly those young people, whose brains are still fully developing and who are very impulsive, who are a cause for great concern.
“Strict adherence to the duty of care, therefore, remains one of our top priorities for the legal market. It goes without saying that the illegal sector does not care in any way about the harm that gambling can cause.”
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