The 'Dutch disaster': experts on over-regulation and black market
At the conference hosted by the Swedish Trade Association for Online Gambling (BOS), Peter-Paul de Goeij, who founded the Netherlands Online Gambling Association (NOGA), delivered a riveting and, at times, sobering assessment of what he calls the “Dutch disaster” in online gambling regulation. Drawing on data, legislative history, market shortcomings, and rising consumer risks, de Goeij issued a powerful warning to policymakers and industry stakeholders across Europe. Madeleine Tügel, Chairperson of the Swedish Association of Gambling Addicts, and Pontus Lindwall, CEO of Betsson, took part in the conversation.
Half of Dutch online gambling happens on illegal platforms
“The Netherlands is a small country,” de Goeij began. “But it has every reason to be a thriving online gambling market.” He reminded the audience that despite its modest size, the Netherlands has a dense population, a trillion-dollar GDP, and a longstanding appetite for online gambling dating back to the early 2000s.
Yet, rather than flourish post-regulation, the Dutch market has floundered. According to de Goeij, official figures show that only 49% of online gambling revenue goes to licensed operators—meaning the majority flows into unregulated, illegal channels. “Regulation isn’t for the benefit of operators. It’s for protecting consumers – and failing to protect 50% is a failure,” asserted Pontus Lindwall, CEO of Betsson.
Meanwhile, growth has also stalled. While European countries reported an average 15% growth in 2024, the Netherlands managed only 4.9%. Gross gambling revenue (GGR) is plummeting. State-owned Holland Casino reported a €10.4 million loss, openly attributing it to rising taxes and tighter regulations. “The auditor warned: there are serious doubts about Holland Casino’s future,” explained de Goeij.
Death by taxes
One of the core problems, according to de Goeij, is a series of well-intentioned but poorly executed policies. “Death by taxes,” he called it, referring to the rising gambling tax that will hit nearly 38% in 2025. Alongside this, restrictions have piled up: advertising bans, the ban on “role model” promotions, and the introduction of deposit limits and affordability checks.
“At registration, there is a limit of 350 euros per month,” de Goeij explained. Young adults are capped at 150 euros, and going over 700 euros requires submitting financial proof. The results? A mass migration to illegal sites. “Deposit limits have triggered the migration to illegal markets,” he declared.
A failure to learn from Denmark
While Dutch regulators looked to Denmark for inspiration, they failed to adopt its stability and effectiveness. “We didn’t take the best parts of Danish regulation,” de Goeij lamented, criticising both the implementation and the political climate that let fear and assumptions shape policy. “Policies have to be fact-based and sustainable regulation needs a competitive legal market.“
Advertising backlash and market confusion
The Dutch advertising market exploded early, dominated by incumbents like the State Lottery and Holland Casino. “They blew up the advertising market, and politically, this led to a pushback.” Now, with a near-total ad ban set to hit by 1 July 2025, de Goeij warned of the consequences: “72% of Dutch citizens already can’t distinguish between legal and illegal operators.”
Without advertising visibility, he argued, the legal market becomes invisible. “If you don’t exist in the consumer’s frame of recognition, you’re lost.”
“We must inform consumers that playing with a Swedish-licensed company offers protection,” agreed Madeleine Tügel, chairperson of Spelberoendes Riksförbund, the Swedish Association of Gambling Addicts. “Gambling is not a regular commodity. It’s addictive and has serious social consequences. We must take action against the leakage to the unregulated market – otherwise, legislation is meaningless.“
Political apathy
During the panel, de Goeij expressed frustration at the lack of urgency from regulators and politicians. “It hasn’t sparked any political upheaval—just a ‘nothing to see here, move along’ attitude,” he said. He added that even as channelisation has dropped below 50%, regulators continue to claim progress: “The KSA [the Dutch regulator] said, ‘We can see the limits are working.’ To me, that was a huge shock.”
Both Lindwall and Tügel urged more open dialogue between the industry and regulators. “In Sweden, we [operators and regulators] play for the same team. Dialogue is critical,” stated Pontus Lindwall.
Lessons for Europe
The Dutch experience is a cautionary tale for other European countries. “Gambling regulation, more than any other regulation, is a balancing act,” de Goeij concluded. “We have to make sure that we come up with measures to prevent people from sliding off to the illegal market.“
