The Kansspelautoriteit (Ksa) has updated its good and bad practices document for the affordability test (affordability test), following a round of targeted audits that uncovered persistent compliance gaps alongside genuine improvements.
Background: Mandatory Affordability Test Checks Since October 2024
Since October 2024, online gambling operators licensed in the Netherlands have been required to conduct an affordability test when players seek to deposit more than set thresholds net. The limits are €300 for young adults aged 18 to 24 years, and €700 for players aged 24 and older. The test is designed to prevent players from gambling beyond their financial means.
Follow-Up Audits Across 20 Dutch Licensees
Good and bad practices draagkrachtoetsen zorgplicht 2026 (PDF - 151.78 kB)
The table below summarises the two deposit threshold tiers that trigger a mandatory affordability check under Dutch gambling regulation, along with the player age groups each tier applies to.
| Player Age Group | Monthly Net Deposit Threshold | Affordability Test Required |
|---|---|---|
| 18 – 24 years (young adults) | €300 | Yes — mandatory above this amount |
| 24 years and older | €700 | Yes — mandatory above this amount |
Both thresholds apply on a per-month, net deposit basis — meaning operators must track cumulative deposits, not individual transactions, to determine when an affordability check is triggered.
How the Dutch Affordability Test Fits Into the Wider KOA Framework
The affordability test was introduced under the Netherlands' Remote Gambling Act (KOA Act), which came into force in October 2021. The affordability test is one layer within a broader responsible gambling architecture that also includes cooling-off periods, deposit limits, and mandatory registration with CRUKS — the central exclusion register. The Netherlands is one of the few EU markets to mandate income-based financial checks as a licensing condition rather than leaving them to operator discretion.
The Ksa first published its good and bad practices framework in February 2025. Subsequently, the authority conducted follow-up sampling investigations at 20 licensed operators, reviewing concrete affordability test cases in detail.
The results were mixed. The Ksa acknowledged positive movement — many operators had adjusted their procedures in response to the initial guidance. However, violations and areas requiring improvement were also identified. In total, the authority applied the following enforcement measures across the audited licensees:
- 10 improvement discussions with various operators
- 3 formal warnings
- 1 binding instruction
These figures reflect an escalating enforcement posture — the Ksa's earlier AML directive to Unibet over compliance failures earlier this year signalled that the regulator is willing to move swiftly from guidance to binding action when operators fall short.
Key Clarification: Savings Do Not Count in the Affordability Test
The updated guidelines introduce an important clarification that had caused confusion in practice: liquid assets, including savings, may not factor into an affordability test assessment. The evaluation must be based exclusively on a player's structural income. This distinction had previously generated uncertainty among operators.
The revised document is available for download:
The PDF — Good and bad practices draagkrachtoetsen zorgplicht 2026 — is 151.78 kB.
Practical Compliance Tip: Acceptable Income Documentation
To align with the structural income standard, compliance teams should accept only recurring, verifiable income sources — such as payslips, pension statements, or tax authority records — as evidence. One-off bank balances, investment portfolios, or savings account screenshots are now explicitly outside the permitted evidence set. Operators should update their internal verification checklists and retrain customer-facing staff before the next Ksa sampling round begins.
What Dutch Operators Should Prepare For Next
The Ksa is explicit that this subject will remain under active supervision. A further round of sampling at licensees is already planned on the back of the updated guidelines.
For compliance teams, the income-versus-assets distinction is the most operationally significant update. Operators who have been factoring in savings balances to justify higher deposits are now on notice. With enforcement escalating from improvement discussions to binding instructions, the next audit cycle carries heightened risk for those who have not aligned their processes to the structural income standard. This regulatory trajectory mirrors the broader Dutch market stagnation concerns the Ksa has flagged, where tightening compliance burdens continue to reshape the competitive landscape.
According to KSA.
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