Dutch Gaming Market Stagnates as Illegal Share Rises to 47%

The Netherlands' online gambling market has reached a concerning inflection point, with legal operators losing ground to illegal competitors despite regulatory efforts to strengthen player protections. The latest monitoring report from the Dutch gambling authority KSA reveals a market in stagnation, where policy measures intended to safeguard consumers may be inadvertently driving players toward unregulated alternatives.

Legal Market Hits Plateau

The tenth edition (tenth edition) of the Ksa's biannual monitoring report paints a picture of a legal market that has essentially flatlined. Key metrics including the number of licence holders, turnover, player numbers, and channelisation rates remain virtually unchanged from the previous reporting period, cementing the downturn that began with regulatory interventions in 2024.

This stagnation follows the implementation of deposit limits and the gambling tax increase introduced in 2025, measures that appear to have fundamentally altered market dynamics. The policy interventions have achieved one notable success: average monthly losses per player have continued their substantial decline, holding steady at approximately €120 per month in the second half of 2025 – roughly one quarter less than 2024 levels.

Illegal Market Gains Ground

However, the most alarming development concerns the growth of illegal gambling operations. While the number of Dutch players exclusively using legal operators remains high, the Ksa estimates a slight decline in this crucial metric. More significantly, the financial flows tell a troubling story.

At the beginning of 2025, legal operators captured 56% of total gross gaming revenue (BSR). By the second half of the year, this figure had dropped to 53%, meaning nearly half of all money gambled in the Netherlands now flows to illegal operators.

"This means that nearly half of what is gambled in the Netherlands appears to flow to illegal parties."

— Michel Groothuizen, Ksa Chairman

This trend mirrors global patterns, where illegal market share is expanding across multiple jurisdictions. The Ksa attributes this growth to technological developments including artificial intelligence and emerging phenomena like cryptocurrency gambling, which provide illegal operators with sophisticated tools to attract and retain players.

Unintended Consequences of Player Protection

The regulatory measures designed to protect consumers appear to be generating unexpected side effects. While deposit limits per operator were not initially driving multi-account creation, recent data shows players are now opening additional accounts to circumvent these restrictions.

This behaviour suggests that financial affordability checks triggered at certain spending thresholds may be pushing some players to either spread their activity across multiple legal operators or abandon the regulated market entirely. The Ksa acknowledges this presents a significant policy challenge: maintaining robust player protections while preserving the attractiveness of legal gambling options.

Political discussions are increasingly focused on implementing an overarching spending limit that would prevent players from hopping between different legal operators. However, such measures would not address migration to illegal platforms, where spending controls are non-existent.

Persistent Vulnerability Among Young Players

The monitoring data reveals concerning patterns in player demographics. Approximately 6% of the adult population gambles online, with high-risk gamblers representing the largest segment within this group. Most troubling is the finding that 18-year-olds have the highest relative number of gambling accounts of any age category.

This concentration among the youngest legal gambling demographic raises serious concerns about long-term harm, particularly given ongoing brain development and heightened impulse sensitivity in this population. The Ksa emphasises that duty of care obligations remain paramount, especially as illegal operators show no regard for potential gambling harm.

Strategic Challenges Ahead

The current market dynamics present Dutch regulators with a complex balancing act. Maintaining visibility for legal gambling options appears essential – ruling out comprehensive advertising bans – while simultaneously intensifying enforcement against illegal operators. The authority rejects any relaxation of duty of care measures for licensed operators, viewing strict compliance as fundamental to market integrity.

The Ksa's stance reflects broader challenges facing European regulators as they navigate between consumer protection and market competitiveness. With illegal operators leveraging technological advantages and regulatory arbitrage, traditional enforcement approaches may prove insufficient.

Regulatory Implications for European Markets

The Dutch experience offers critical insights for other European jurisdictions implementing online gambling frameworks. The apparent trade-off between stringent player protection measures and market channelisation suggests that regulatory design requires careful calibration to avoid unintended migration to illegal platforms.

The Netherlands' struggle with illegal market growth, despite having established a comprehensive licensing regime, highlights the limitations of domestic regulation in addressing global illegal gambling operations. This dynamic may necessitate enhanced international cooperation and more sophisticated technological countermeasures. For operators across Europe, the Dutch case study underscores the importance of demonstrating clear value propositions to consumers beyond mere legal status, particularly as regulatory compliance costs continue to increase while illegal competitors operate without such constraints.

According to KSA.