A Dutch Disease? Constant Regulatory Reform in Online Gambling

The Dutch Remote Gambling Act entered into force on 1 April 2021 after an initial bill was tabled already in 2013. The market ultimately opened on 1 October 2021. The framework promised a balanced focus on channelisation, consumer protection, and tax revenue. What followed, however, was not a period of growth and consolidation but a phase of repeated policy changes and eventual decline.

Early optimism

The Netherlands began on a similar track to other European online gambling markets. As planned, channelisation rose quickly and the Dutch Gambling Regulator ‘Kansspelautoriteit’ (KSA) reported that four out of five players used licensed operators. Yet within months, political pressure, often based on fear and assumption rather than evidence, drove further restrictions on the fledgling regulated market.

In April 2022, the government banned the use of role models in gambling advertising, such as athletes, influencers and celebrities. Trade bodies NOGA and VNLOK introduced unprecedented self-regulation, limiting the number of online gambling ads on television per commercial block and ending all radio, outdoor, and print advertising by 1 July 2022. One year later, on 1 July 2023, a general ban on all untargeted advertising was imposed. On 1 July 2024, sponsorship of television programmes and events was prohibited, and on 1 July 2025 sports sponsorship came to an end. Meanwhile, strict new duty of care obligations, spending limits and affordability checks came into force on 1 October 2024.

Signs of slowdown

The impact was immediate. Market data show that in the first half of 2024, GGR continued to rise. In the second half, after the new limits took effect, GGR dropped by ten percent. Full-year growth was still positive, around six percent compared to 2023, but the momentum broke. Instead of a young market showing strong expansion, the Dutch market flattened in its third and fourth years.

In March 2025, the KSA reported that channelisation, measured by GGR, had fallen below 50 percent. This means that more than half of Dutch online gambling spend now flows to unlicensed operators abroad. The illegal offer has grown spectacularly since 2023, undermining both consumer protection and fiscal stability.

Reports show that unlicensed operators are increasingly visible and accessible, often promoted through mainstream digital channels. A striking factor is the lax approach taken by Google and other major platforms in allowing advertising for illegal services to reach Dutch consumers. This pattern is not unique to Google but applies to large tech platforms more broadly. The result is a tilted playing field: licensed operators face strict limits and heavy compliance costs, while illegal operators advertise freely and capture market share. Ultimately, Dutch consumers pay the price.

Fiscal paradox

Fiscal results underline the same story. The government increased the gambling tax rate from 30.5 to 34.2 percent on 1 January 2025. Despite this higher rate, the Budget of September 2025 (Miljoenennota 2026) projects only around €1.0 billion in gambling tax revenue – down 23.2 percent compared with earlier forecasts and essentially equal to 2024. For 2026, the projection has again been lowered by over 23 percent. In plain words: the treasury collects less gambling tax while taxing more. This loss in public revenue directly benefits foreign illegal operators, who gain Dutch consumers as the legal offer becomes less attractive.

International comparison

To illustrate the structural difference with other European markets, the following chart compares the first years of growth in newly regulated online markets. The UK (regulated from 2005), Denmark (2012), and Sweden (2019) all displayed strong early growth trajectories. The Netherlands, by contrast, is already underperforming – diverging sharply from the expected curve.

The Dutch numbers are striking. In a newly regulated market, roughly four years old, early growth should be in double digits. That is what we saw in the UK, Denmark, and Sweden. Dutch consumers are no different from other Europeans, yet the growth trajectory has dropped too dramatically. GGR was already shrinking in Q4 2024 and the outlook for 2025 is contraction rather than expansion. Instead of convergence with its European peers, the Netherlands is diverging.

A Dutch Disease

This is the Dutch Disease of gambling regulation – a term borrowed from economics but here describing a different condition, where constant political interventions create instability that undermines consumer protection, channelisation, and fiscal returns. Instead of steady growth, regulation itself has become the illness. Players drift back to the illegal offer, consumer protection weakens, and tax income falls. The intended gains of legalisation are reversed by the volatility of policy.

Towards stability

The solution is equally clear. Policymakers should not shy away from undoing unwise measures and correcting earlier missteps. Consumers deserve a functioning legal market. Rolling back well-intentioned but counterproductive interventions, including reconsidering the recent gambling tax increase, would restore balance. A multi-year freeze on further changes, combined with independent evaluation of outcomes, stronger enforcement against unlicensed operators, and clear obligations on platform providers and banks to block illegal services, would provide stability.

Stability is not weakness; it is strength. Only with stability can the Netherlands achieve the goals it set out in 2013: safe play on a fair market, high channelisation, and sustainable public revenue.

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Author Bio: Peter-Paul de Goeij is a consultant and advisor specialised in legal, regulatory and public affairs in the gambling sector. He is the owner of Quod Bonum Consulting and serves on several advisory boards. With extensive experience in change management and industry representation, he has been closely involved in the debate on gambling regulation in the Netherlands and Europe.

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