KSA Study Reveals Shortcomings in Dutch Online Gambling Safeguards
The study found that current risk analyses for online gambling in the Netherlands are falling short of expectations. Risk analysis systems put in place by licensed online gambling operators are “not functioning properly” and do not offer adequate and “effective” protection to players, according to a new study conducted by regulator Kansspelautoriteit (KSA).
The report, published on Friday, focused on systems currently in place across operators that hold a Dutch online gambling licence. Research took place during 2024 and 2025, with the aim of determining whether the analysis measuring systems suitably helped to protect players from harms. Such systems are part of the duty of care requirements that apply to all licensed operators in the Netherlands. They must determine the level of risk associated with so-called “high-risk games” such as online slots, and based on this assessment, they must implement measures to help prevent harms.
The report questioned the associated costs of the systems. KSA said conducting the risk analyses required “significant” effort and expense for a licensee, while only providing “little” additional protection for the player. Setting out its primary concerns, KSA said the methods for carrying out risk analyses remain “under debate”. It identified five different methods, with the most popular systems being ‘Asterig’ and ‘Gamgard’.
Asterig was established in 2010 and further developed in 2013, and is publicly available to all operators. KSA said while it delivers consistent results, there are concerns over reliability, validity, and applicability, adding it is “insufficiently substantiated”. Limitations include the criteria used and scoring scales. As for Gamgard, KSA said this should be regarded only as a preliminary screening, as only a limited number of potential risk factors are assessed. Researchers questioned its validity and transparency, adding that it is not publicly available.
“These methods originate from a time when the online market in the Netherlands was not yet legalised,” KSA said. “As far as KSA could establish, these methods have not been further developed since the opening of the Dutch online market on 1 October 2021. Although academic articles raised concerns about these methods at the time, no new or alternative methods have emerged to date.”
The regulator found that nearly all licensees conducted their risk analysis by game category rather than for each individual game to save time and costs, and because they found game styles within each category did not differ very much. KSA took issue with analysis not being conducted per game, noting that analysis at the game category level could lead to some games being assigned too low a risk level. However, current regulations do not contain any rules on this specifically.
Operators were found to use a mixture of external and internal analysis for these player risks. The KSA found 21 licensees used an external analyst, while seven conducted the whole of the risk analysis internally. The regulator also took issue with how operators presented different outcomes for the same games. During the study, licensees used six different consultancies and consultants, with the analyses differing across certain operators. This, KSA said, was the case even when the same games were being analysed.
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Analyses differ by licensee, even when the same consultancy/consultant is used,” KSA said. “As these often concern the same games, it appears that the risk analyses do not lead to consistent results, even when conducted by the same party.” Off the back of this, the regulator flagged how the outcomes of risk analyses across operators are not comparable. This was partly due to some licensees taking mitigating measures into account, and others not. As such, KSA questioned whether the licensees are correctly assessing the risk of the games they offer.
A further concern related to how independent and expert conduct of analyses is not always “adequately guaranteed.” KSA said uncertainty as to who was considered “independent” was an issue, while the expertise and knowledge of some external analysts was “insufficiently clear.” As such, KSA concluded the current system is not up to scratch. It said it is already in talks with the Dutch Ministry of Justice and Security about future improvements. KSA added that its long-term aim is for a “uniform system” to determine risk analysis for online games.
