In a revealing study conducted by the Kansspelautoriteit (KSA), the regulator overseeing gambling in the Netherlands, it was found that the risk analysis systems employed by licensed online gambling operators are not adequately protecting players. This comprehensive review, spanning 2024 and 2025, scrutinized the effectiveness of existing systems designed to shield players from gambling-related harms.
KSA’s report highlighted that these systems, part of the mandatory duty of care for all licensed operators, are supposed to evaluate the risk levels of high-stakes games like online slots. Based on the assessed risk, operators are required to institute protective measures. However, KSA found the current implementations wanting, both in functionality and cost-effectiveness. The study noted that the substantial effort and expense required for these systems result in minimal additional protection for players.
The KSA critically assessed the methods operators use for risk analysis, which remain contentious. Among the five identified methods, ‘Asterig’ and ‘Gamgard’ are the most commonly used. Asterig, developed in 2010 and updated in 2013, is accessible to all operators and delivers consistent results. Yet, KSA raised concerns about its reliability and applicability, pointing out its “insufficient substantiation” and questioning the criteria and scoring scales employed.
Regarding Gamgard, KSA cautioned that it serves only as a preliminary screening tool, assessing a limited range of potential risk factors. The study questioned Gamgard’s validity and transparency, especially since it is not publicly accessible. The KSA remarked that these methods date back to a period before the legalization of the Dutch online market on October 1, 2021, and have not evolved since then, despite academic critiques.
The investigation further uncovered that operators often conduct risk analysis by game category rather than by individual game. This approach, while cost-effective, risks underestimating the risk levels of particular games. KSA found that 21 licensees used external analysts, whereas seven conducted risk analyses entirely internally. The lack of consistency and thoroughness in these analyses was a significant point of concern for KSA.
Discrepancies in the outcomes of risk assessments were another critical issue. During the study, operators employed six different consultancies, yet results varied even for the same games, indicating a lack of standardization. The KSA noted, “Analyses differ by licensee, even when the same consultancy/consultant is used. 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.”
Such variability makes it challenging to compare risk assessments across operators. The KSA attributed this to some licensees considering mitigating measures, while others did not. This inconsistency led KSA to question whether operators are accurately evaluating the risks of the games they provide. Concerns about the independence and expertise of external analysts further complicated the issue, as KSA noted instances where the qualifications of analysts were unclear.
In light of these findings, KSA acknowledged that the current system needs significant improvements. The regulator is already in discussions with the Dutch Ministry of Justice and Security to enhance these systems. KSA’s long-term vision is to establish a “uniform system” for risk analysis in online gambling.
However, there is also a counterpoint to consider. Some experts assert that the diversity of methods and independent assessments can foster innovation and adaptability in risk management. They argue that a one-size-fits-all approach may stifle the flexibility needed to address the unique aspects of different games and player behaviors. These experts suggest that instead of uniform methods, there could be standardized guidelines that allow operators the autonomy to tailor their strategies while ensuring a baseline level of protection.
Nevertheless, the pressing need for reform remains clear. As the Dutch online gambling market continues to grow, ensuring robust and effective protective measures is crucial. The KSA’s findings serve as a wake-up call to operators and regulators alike, emphasizing the importance of evolving risk analysis tools and techniques that can keep pace with the dynamic nature of the gambling industry.
Operators are now faced with the challenge of not only complying with regulatory demands but also ensuring that their risk analysis systems genuinely benefit the players they aim to protect. As talks progress between KSA and governmental bodies, stakeholders in the Dutch gambling industry must navigate these changes carefully, balancing regulatory compliance with innovative approaches to player safety. The journey towards a more secure and responsible gambling environment is ongoing, and the eyes of both regulators and the public will be closely watching how operators respond to these challenges.
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