De Kansspelautoriteit (Ksa) has issued a last onder dwangsom — an order backed by incremental financial penalties — against a company conducting illegal promotional gambling through repeated car raffles.
The Violation
The company regularly raffled cars among customers who had purchased products or services above a minimum spend threshold. That purchase requirement alone breached Dutch promotional gambling rules, which mandate that participation must always be free. Operators are also restricted to promoting a single product, service, or company just once per year through such draws, and must publish participation terms on their website.
The Ksa received multiple complaints before opening its investigation. Regulators met with the company owner and clearly explained the applicable rules and potential consequences of continuing. Despite that direct warning, the company organised further draws.
Enforcement Outcome
Warning
The Ksa identified not one but three distinct rule violations by this operator: (1) charging a minimum spend as entry, (2) running promotional draws more than once per year for the same entity, and (3) failing to publish participation terms publicly. Each element on its own is sufficient to trigger enforcement — combining all three substantially increases regulatory risk.
The regulator has now issued the formal enforcement order, demanding the company cease all raffle activity immediately. Failure to comply carries a penalty of €150,000 per violation, capped at a total of €450,000.
€150,000
Penalty per individual violation
€450,000
Maximum total penalty cap
3
Violations identified by the Ksa
A Clear Signal on Promotional Mechanics
This case illustrates that purchase-linked giveaways are not a grey area under Dutch law. The Ksa's willingness to escalate after direct engagement signals that companies which ignore regulatory dialogue should expect formal, financially significant consequences. This pattern mirrors the regulator's broader enforcement posture — the Ksa recently issued an AML directive to Unibet over compliance failures, similarly acting only after warnings were disregarded. Operators structuring loyalty or promotional mechanics in the Netherlands would do well to audit whether their prize draws genuinely meet the free-entry and frequency requirements.
Compliance Checklist for Dutch Prize Draws
Before launching any promotional draw in the Netherlands, verify: entry is entirely free and requires no purchase or minimum spend; the same brand runs no more than one such draw per calendar year; and full participation terms are published on the company website prior to the draw opening. Missing any single criterion puts the promotion outside legal bounds.
According to KSA.
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