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“They challenge us both from an academic side and a more practical side. We try to develop our rules as we go along but you have to prove every single day that you’re doing all that you need to do on responsible gaming,” Petra notes.

The Netherlands online gambling market has been the subject of many column inches and much speculation thanks to regulation that has been largely described as heavy-handed and perhaps a little short-sighted – even by the country’s own regulator.

The triumvirate of Netherlands, Germany and Sweden is often held up as an example of how not to regulate, with all three countries haemorrhaging players to waiting illegal operators. So what is public sentiment like towards operators? “My feeling is that if you look at public sentiment, they don’t see really the difference between online and land-based,” says Petra. “If you look into what they’re saying, they’re primarily talking online. But for the general public, there is no difference [between the channels] in that respect.”

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One such rule was for licensees that had faced compliance enforcement during the five years operating in the Netherlands.

At the time KSA announced: “Providers that made mistakes in the past five years must explain during the application process how they have learned from previous mistakes and how they intend to prevent recurrence. If we find this explanation insufficient, the permit may be denied or additional conditions and restrictions may be imposed.” 

This requirement raised concerns among operators worried that the barriers to entry could have become more restrictive, But at a meeting on the policies last year the regulator assured licensees it was not enforcing a specific strict rule on this.

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Promotions and benefits: Bonuses, promotional credits, free bets, cashback, free spins, rewards and loyalty programmes used to encourage membership, retention or return to betting are prohibited.

Misleading messages: Messages that present betting as a risk-free activity, a source of income, a financial solution, a sure profit, a guaranteed method or a way to recover losses cannot be disseminated.

The restriction does not extend to strictly institutional communication made through the authorised operator’s own official channels, such as websites, apps, internal platform areas and customer service channels. In these spaces, information should be limited to company identification, official channels, access rules, self-exclusion and blocking mechanisms and mandatory warnings.