Nederlandse Loterij said on Tuesday it had ordered the operators and directors behind the unauthorised Skyhills gambling website to stop accepting customers in the Netherlands, citing the recent Dutch court ruling against Lalabet as support for its action. The move matters because it tests whether civil litigation by a state-backed licensed operator can complement regulatory enforcement against offshore sites that target Dutch players without a licence.
The lottery operator said it issued cease-and-desist notices to entities and individuals connected to Skyhills in Costa Rica, North Macedonia, the United Kingdom, Curaçao, Malta and the Marshall Islands. According to Nederlandse Loterij, the Skyhills website became inaccessible from the Netherlands after the notices were sent.
Skyhills does not hold a Dutch remote gambling licence. Under the Netherlands’ regulated online gambling system, operators seeking to offer games of chance to Dutch consumers must be authorised by the Kansspelautoriteit, the Dutch Gambling Authority. Licensed businesses are subject to requirements concerning player verification, responsible gambling controls, advertising, financial integrity and reporting.
Nederlandse Loterij said its intervention followed evidence that Skyhills had actively pursued Dutch consumers, including through social media advertising. Chief executive Arjan Blok said the platform had used TikTok marketing that was directed at Dutch players, with particular concern around younger audiences. He argued that customers using unauthorised sites could be exposed to gambling products without the safeguards required of licensed operators.
The action against Skyhills is the third such case pursued by Nederlandse Loterij, following legal steps involving Lalabet and Qbet. While the state-backed operator is itself a participant in the licensed market, its campaign also reflects mounting concern among regulated businesses that illegal websites can operate with lower compliance costs while seeking the same Dutch customer base.
The Lalabet judgment, issued in June, has become central to the lottery operator’s legal strategy. In that case, a Dutch court found that companies and directors linked to the Lalabet platform had acted unlawfully by targeting players in the Netherlands without the required market access. The court ordered the parties to halt their activities directed at Dutch consumers and to provide information about ownership and shareholding arrangements.
That ruling was significant because it went beyond a finding against the gambling platform itself. The proceedings also examined the role of corporate service providers, trust administrators and local representatives that can be involved in the structure and administration of offshore gambling businesses. Such intermediaries may not operate gambling products directly, but their services can be relevant when authorities and claimants seek to identify the parties responsible for an unauthorised website.
The court did not hold Curaçao-based trust company DECC and its directors liable in the Lalabet case. However, Nederlandse Loterij has interpreted parts of the ruling as a basis for closer scrutiny of firms that provide administrative or corporate support to gambling operators serving prohibited markets. The lottery operator said it plans to appeal aspects of the judgment, including the court’s assessment of the due diligence obligations of trust companies when accepting clients.
Its review of DECC’s possible connections to Qbet and Skyhills could result in further proceedings, depending on the information obtained about those platforms’ corporate structures. The issue is likely to be closely watched by offshore corporate service providers, particularly those with clients operating under licences issued outside the European Union. Civil claims can require detailed disclosure that may be difficult for claimants and regulators to secure through conventional enforcement routes.
The Netherlands opened its regulated remote gambling market in October 2021, allowing licensed operators to offer online casino games, betting and poker under the Remote Gambling Act. The framework was designed in part to channel consumers away from unregulated websites and into services subject to Dutch supervision. That objective has faced sustained pressure from the continued availability of offshore platforms, including sites that use Dutch-language content, local payment options or online advertising aimed at the country.
The Gambling Authority has powers to impose administrative fines and issue other enforcement measures against operators that illegally target the Dutch market. It assesses a range of factors when determining whether a platform is focused on the Netherlands, including the use of Dutch language, Dutch domain names, local symbols, payment methods and failures to block Dutch internet traffic. Enforcement against businesses based in multiple jurisdictions can nevertheless be complicated by opaque ownership structures, technology suppliers and payment arrangements located outside the regulator’s direct reach.
Nederlandse Loterij has welcomed proposals in The Hague to strengthen the regulator’s powers, but has warned that major legislative amendments may take time to take effect. The Dutch House of Representatives was due to debate gambling reforms this week, including measures intended to improve the state’s response to illegal online supply. The company has called for action beyond administrative enforcement, including criminal investigations by the Public Prosecution Service where evidence supports prosecution.
Blok also said payment companies, banks and hosting providers should assume greater responsibility for services used by illegal gambling platforms. The argument reflects a wider policy debate across Europe over whether enforcement should focus more heavily on the infrastructure supporting unlicensed gambling, rather than only on the websites themselves. Payment blocking, advertising restrictions and measures directed at hosting or software providers can disrupt access, but each approach raises practical questions around legal authority, cross-border cooperation and proportionality.
The advertising issue has become particularly contentious in the Netherlands. Nederlandse Loterij has criticised proposals for a broad prohibition on advertising by licensed online gambling companies, arguing that reduced visibility for regulated providers could make it harder for consumers to distinguish authorised sites from illegal alternatives. The company says unlicensed operators have captured about half of the Dutch online gambling market and account for around 95% of online gambling advertising, often presenting themselves in ways that can appear similar to licensed businesses.
Those estimates have not been independently verified in the announcement, but they underline the commercial pressure facing the regulated sector. Nederlandse Loterij has suggested that approximately 200,000 people in the Netherlands use unauthorised gambling websites. If the illegal market is approaching the scale of the licensed market, it would challenge the channelisation objectives that underpinned the 2021 legislation and could reduce the effectiveness of Dutch consumer protection requirements.
The Dutch Online Gaming Providers association, VNLOK, has also sought action against digital advertising channels. Earlier this summer, the trade body brought legal proceedings against Meta and filed a complaint with the European Commission, alleging that Facebook and Instagram had not adequately prevented illegal gambling advertisements from reaching Dutch users. VNLOK said the unlicensed online gambling segment was now comparable in size to the regulated market, estimating annual revenue across the sector at more than €1bn.
Digital platforms are likely to face continued demands from licensed operators and policymakers to improve the detection and removal of ads for unauthorised gambling services. However, enforcement against advertising can be difficult where campaigns are distributed through affiliates, influencers, short-lived accounts or targeting tools that are not always transparent to users. The reference to TikTok in the Skyhills case may increase attention on the effectiveness of age controls and advertising moderation on social media services.
For licensed operators, the Skyhills case illustrates both the value and the limits of private legal action. A cease-and-desist demand that leads to a website blocking Dutch access can deliver a rapid result, but it does not necessarily resolve questions about payments, mirror sites, affiliate activity or the ability of the same operators to reappear under another brand. Civil litigation can also be expensive and dependent on identifying the relevant companies, directors and service providers across several jurisdictions.
The next steps will depend on whether Skyhills remains inaccessible to Dutch users and whether Nederlandse Loterij proceeds with further claims connected to Qbet, Skyhills and corporate intermediaries. Parliament’s discussion of gambling reforms, potential action by the Gambling Authority and any appeal in the Lalabet matter will determine whether the Netherlands develops stronger tools for addressing unauthorised operators and the businesses that support them.
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