Netherlands Gambling Affiliates: No Licence, Strict Rules

Is there a gambling affiliate licence in the Netherlands? No — and none is even proposed. But that “no” is the least useful answer in European affiliate compliance. The Kansspelautoriteit (KSA) treats affiliates as a supervised part of the gambling ecosystem: promote an unlicensed operator and you commit your own criminal offence; promote a licensed one and you inherit a strict advertising rulebook enforced with weekly penalty orders, six-figure forfeitures and domain takedowns. The Netherlands is, by some distance, the most heavily policed “unlicensed” affiliate market in Europe — and a 2027 law revision may tighten it further.

No licence — and none on the table

The Remote Gambling Act (KOA), in force since 1 October 2021, licenses gambling operators. It created no licence, registration or approval for affiliates, and the ICLG Netherlands Gambling 2026 chapter confirms the position as of late 2025: affiliates do not require individual licences. Nothing in the current legislative pipeline proposes one either.

That makes the Netherlands structurally different from the handful of markets where a formal affiliate credential actually exists — Romania’s ONJN Class 2 licence at roughly €35,000 a year, or Gibraltar’s new GOSS licence, which made marketing services a licensable activity from 1 October 2025. For the full country-by-country picture, see our guide to whether gambling affiliates need a licence.

One caveat on labels: you may encounter the KVA (Keurmerk Verantwoorde Affiliates), a quality mark for “responsible affiliates”. It is a private, voluntary label run by XY Legal Solutions B.V. — it carries no legal effect and is not a substitute for compliance with anything below.

Two ways to get in trouble

Dutch affiliate exposure runs on two separate tracks, and the first one is the sharper of the two.

Track one: promoting unlicensed operators is your own offence

KOA expanded Article 1(1)(b) of the Betting and Gaming Act (Wok) to cover facilitation of unlicensed remote gambling. An affiliate who sends traffic to an operator without a KSA licence is not an accessory to someone else’s violation — the affiliate is an offender in its own right. An earlier, pre-KOA case involving the Spinity affiliate programme — reported as a €100,000 fine for promoting an illegal operator — showed the KSA was willing to fine affiliates directly even under the old law.

The stakes have since gone up. Under the KSA’s fining policy in force since 1 January 2025, base fines range from €500 to €2,000,000, with an option to add 3% of turnover. Add penalty orders (more on those below) and domain takedowns, and “we’re just a media company” stops being a defence.

Track two: promoting licensed operators means chain responsibility

Affiliates working with KSA-licensed operators are legal — but they operate inside the operator’s compliance perimeter. KSA guidance requires the operator to have a written agreement with the affiliate before the cooperation starts, stipulating among other things that no vulnerable groups will be targeted. The licence holder remains responsible for violations committed through its affiliates, which in practice means audits, evidence requests and immediate termination clauses flowing down the chain to you.

The advertising rulebook that binds affiliate sites

The framework is the Decree on recruitment, advertising and addiction prevention (Bwrvk), significantly amended by the Besluit ongerichte reclame — the “Besluit orka” — in force since 1 July 2023. The orka decree banned untargeted gambling advertising outright: no TV, no radio, no print, no outdoor.

Internet and on-demand advertising survived, but only under three cumulative conditions set out in Article 2ab Bwrvk:

1. Recipients must have a real opt-out from gambling advertising;
2. The advertiser must take the best available measures to keep minors, 18–24-year-olds and other vulnerable groups out of the audience;
3. The operator must demonstrate that at least 95% of the persons reached are 24 or older.

Crucially for this article’s readers, KSA guidance explicitly names news and comparison sites and other affiliate websites (“nieuws- en vergelijkingssites of andere affiliate websites”) as a permitted channel — affiliate marketing is not banned in the Netherlands. It is conditioned, and the conditions have teeth.

A ban on role models in gambling advertising has also been in force since 2022 — no athletes, influencers or other public figures in promotions — and the KSA actively enforces it against streamers, as the influencer cases below show.

The March 2026 guidance: 95% is a floor

On 18 March 2026 the KSA published its Leidraad on untargeted advertising, which reads like a checklist written after inspecting affiliate sites. The key points:

• The opt-out must genuinely work: no account required to use it, worded in plain B1-level language, and visibly placed. An age pop-up alone is insufficient.
• 95% is a floor, not a target. Hovering at 95.1% and calling it a day is not the intended reading; the obligation is to keep pushing the under-24 share down.
• If compliance cannot be assured on a given platform, the operator must avoid that platform entirely.
• Measurements must be documented — the operator has to be able to show its audience evidence, which means affiliates must be able to supply analytics that survive scrutiny.

For an affiliate, the practical consequence of that last point is the least obvious and the most important: your operator partners need your audience data to prove their own compliance. An affiliate that cannot evidence its audience composition is an affiliate that compliant operators will drop.

Enforcement: the KSA’s affiliate track record

The Netherlands is not a paper-rules jurisdiction. Here is the affiliate-facing enforcement record in one view:

CasinoScout: the flagship case

CasinoScout was one of the best-known Dutch casino comparison sites, and its fall is the single most instructive affiliate case in Europe right now. On 22 May 2025 the KSA issued orders subject to penalty against three companies behind the site — SBM Holding Group, Sun Block Media Labs 2.0 and JEF Holdings — for promoting unlicensed gambling. The mechanism matters: not a one-off fine, but a rolling €75,000 per week per party, capped at €225,000 each, for as long as the violations continued.

They continued. Re-inspections in July and August 2025 found the site still in breach, and the full cap — €225,000 per party, €675,000 in total — was forfeited. The KSA then had the casinoscout.nl domain taken down through SIDN, the Dutch domain registry. In May 2026, the parties’ objections were declared inadmissible, closing the loop.

Three lessons for any NL-facing affiliate: the KSA pursues corporate structures, not just websites (three separate entities were hit in parallel); penalty orders escalate weekly, so slow remediation is expensive remediation; and domain takedown via the registry means the asset itself — the site — can be switched off.

Influencers are affiliates too

The KSA applies the same logic to individuals. Gambling streamer LeftlanePapi received an order subject to penalty on 18 June 2025, with €25,000 collected by October 2025. On 30 September 2025 three more — Stiefunspeelt, Turcos and Buurtwachtt — received orders at €25,000 per violation, capped at €75,000, with 48 hours to remove the offending content. If your business model involves personalities promoting gambling to a young audience, the Netherlands is not the place to run it.

What’s coming in 2026–2027

Two government letters define the trajectory, and neither is affiliate-friendly.

The Kamerbrief of 14 February 2025 (State Secretary Struycken) announced a course change for Dutch gambling policy: a minimum age of 21 for high-risk games, cross-operator deposit limits, a shift to a “prohibited-unless” advertising regime — and, most relevant here, expanding the norm-addressees of advertising rules to marketing companies, affiliates and platforms. Today only licence holders are formally bound by the ad rules; under the proposal, affiliates would be directly addressable by the KSA for advertising violations, with legislation to be prepared from 2026.

The progress letter of June 2026 (Van Bruggen) went further: the draft bill under preparation contemplates a near-total advertising ban, with exceptions only for the operator’s own website and explicit search results, plus a ban on bonuses. The role of affiliates is explicitly flagged as still under study (“Ook de rol van affiliates wordt daarin meegenomen”). A first consultation draft is expected in H1 2027, per secondary reporting. If the exception list holds as drafted, the classic Dutch casino-comparison model — organic content plus tracked links plus bonus tables — becomes very hard to operate lawfully.

Meanwhile the KSA’s supervision agenda for 2026 announces ecosystem enforcement: influencers, B2B suppliers, payment providers, hosting and platforms. Affiliates should assume they are on that map.

Compliance checklist for NL-facing affiliates

What “compliant” looks like today, drawn from the rules and cases above:

1. Promote KSA-licensed operators only. Anything else is your own offence — with €75,000-per-week orders and domain takedown on the menu.
2. Sign the written agreement before cooperation starts, and expect the operator to audit you against it.
3. Run a real opt-out from gambling ads on your site: no account required, B1-level language, visibly placed. An age pop-up is not enough.
4. Cooperate on audience evidence so the operator can demonstrate that ≥95% of the persons reached are 24+ — and treat 95% as a floor, not a target.
5. Never reach minors, 18–24-year-olds or Cruks registrants. The February 2024 sweep caught affiliate sites on exactly this.
6. No role models — no athletes, streamers or influencers in your promotions.
7. Identify the promoted operator clearly and carry responsible-gambling messaging.
8. Treat bonus promotion as high-risk. A statutory bonus ban is in the legislative pipeline.
9. KVA is optional. The private quality mark may help commercially but has no legal effect.

For how the Dutch position compares with markets that do license affiliates — and what those credentials cost — our affiliate licensing data hub tracks requirements, fees and legal bases by jurisdiction.

Vantegris works with affiliates on exactly this boundary: we audit NL-facing sites against the Bwrvk conditions and KSA guidance, structure operator agreements and audience-evidence workflows, and — where your growth plan runs through markets that do require a credential, from Romania’s ONJN Class 2 to Greece and the US state registrations — we file those applications through our affiliate licensing service. If you are unsure which side of the line your Dutch traffic sits on, talk to us before the KSA does.

Bottom line

The Netherlands answers the licence question with a no and the compliance question with a long list. Affiliates are a permitted, named channel in Dutch gambling advertising — but only for licensed operators, only under a written agreement, and only within the opt-out, audience-protection and 95%-proof conditions of the Bwrvk. The KSA enforces against affiliates directly, escalates weekly, and has shown it will take the domain itself. And the 2027 revision may shrink permitted advertising to almost nothing, with affiliates’ role explicitly under review. No licence has never meant so much regulation.

This article is general information, not legal advice. The Dutch framework is moving — a consultation draft of the revised gambling act is expected in 2027 — and we confirm the current position for your sites and markets at scoping.

This article is for general informational purposes only and is not legal, tax or financial advice. Consult a qualified professional before acting.