Dutch Gambling Regulator Fines EOD Code for Unlicensed Online Gambling

The Kansspelautoriteit (Ksa) announced on October 22, 2026 that it has fined EOD Code SRL €37.25 million for offering online games of chance without a Dutch licence, after finding that the company targeted players in the Netherlands through instantcasino.com and eleven other gambling websites.

The Dutch gambling regulator said in its announcement that the penalty is the highest fine it has imposed to date for illegal gambling offerings. The board’s fine decision, dated October 6, 2026 in The Hague and sent on October 7, 2026, establishes that EOD Code breached the Betting and Gaming Act’s prohibition on offering games of chance without a licence. EOD Code had previously been given an order subject to a penalty payment over the same conduct.

Twelve Websites Aimed at the Netherlands

Ksa supervisors investigated instantcasino.com on November 19, 2024, December 3, 2024, January 28, 2025, March 12, 2025 and July 8, 2025, and again on July 24, 2026 through the alternate address instantcasino17.com. According to the decision, the site was reachable from a Dutch IP address, and supervisors were able to open an account with Dutch address details, deposit money and play casino games and bet on sports, with no technical measures in place to block participation from the Netherlands. One supervisor deposited €20 worth of Bitcoin; the payment instructions were partly in Dutch.

The website stated that EOD Code is registered and regulated in Costa Rica, that Costa Rican law applies and that the courts of Curaçao have exclusive jurisdiction over claims against the company.

A further investigation on April 23, 2026 identified eleven more EOD Code websites: skyhills.com, slotmonster.com, betiro.com, betblast.com, fastslots.com, goldenpanda.com, sambaslots.com, winningz.com, incognitocasino.com, foxygold.com and luckypays.io. Checks on November 24, 2025, May 21, 2026 and June 10, 2026 found that Dutch consumers could create an account, deposit and play on all of them, the decision records.

The decision lists a series of indicators that the offering targeted the Netherlands. “The Netherlands” was offered in the registration country menu, and on the eleven later-identified sites it appeared automatically in the entry field; the Dutch +31 country code accompanied the telephone number field; the terms on instantcasino.com did not exclude the Netherlands; questions asked in Dutch were answered in Dutch; Google data showed frequent searches for the website from the Netherlands; and the payment process on the sites was wholly or partly in Dutch, with options including iDEAL and the Dutch banks ING, Rabobank, ABN AMRO and ASN Bank. Players could deposit in various cryptocurrencies while their account balances were displayed in euros, and the Dutch-language website casinojager.com carried advertising for the offering.

The decision also records that several Dutch influencers promoted skyhills.com, sharing links to the site through their Instagram, YouTube and Discord channels and appearing in TikTok videos carrying Dutch-language text and the site’s logo. The Ksa imposed separate orders subject to penalty on LeftlanePapi on June 18, 2025 and on Turcos, StiefunSpeelt and Buurtwachtt on September 11, 2025 over those promotions.

Earlier Order and Forfeited Penalties

The Ksa sent EOD Code an intention to impose an order subject to penalty on April 10, 2025 and imposed the order on July 29, 2025. It required the company to cease, and keep ceased, the unlicensed offering within four weeks, on pain of a €280,000 penalty per week or part of a week, up to a maximum of €840,000. The grace period expired on August 26, 2025.

Re-checks on September 5, 12 and 19, 2025 showed the violation had not ended, and EOD Code forfeited €840,000, three times the weekly penalty. A letter of October 16, 2025 announcing the intention to collect the forfeited sums went unanswered, and the Ksa ordered collection in a decision of December 11, 2025. No objection was filed, and the regulator’s enforcement register lists the collection decision and the underlying order as irrevocable.

Revenue Estimate, Aggravating Circumstances and the Statutory Cap

EOD Code did not answer a May 26, 2026 request for data, so the Ksa estimated the company’s 2025 gross gaming revenue using a search-volume method it published on February 14, 2025. Under that method, the regulator put 2025 gross gaming revenue from the Netherlands across the twelve sites at €108.4 million and worldwide gross gaming revenue at €373 million.

Under the Ksa’s 2026 fine policy for illegal online gambling, the base fine at that revenue level is 100% of Dutch gross gaming revenue. The decision raised the percentage by 170 points for aggravating circumstances: 50 points for the absence of visible age verification, 20 for offering prohibited games, 10 each for inactivity fees, autoplay and turboplay functions, missing or pre-filled play limits, the level of deposit amounts and the deposit methods offered, and 50 for special circumstances. That produced a fine of 270% of the Dutch estimate, or €292.6 million, rounded down to a multiple of €50,000.

The Betting and Gaming Act caps an administrative fine at 10% of worldwide turnover in the preceding financial year, here €37,298,900. The Ksa therefore moderated the fine from €292.6 million to €37,250,000.

The conduct behind the increases included a €5 monthly inactivity fee charged from the thirteenth month that an account goes unused. As special circumstances, the decision cites withdrawal limits of €4,000 per day, €10,000 per week and €20,000 per month; a fee on withdrawing funds a player had not wagered at least once; terms under which player balances, although kept separate from company funds, could fall into the estate in a bankruptcy; a disclaimer of liability for deviations in game fairness caused by technical faults; and a term allowing EOD Code to appropriate the balance of a player who requests permanent self-exclusion.

The decision describes the unlicensed and unregulated offering as very serious and culpable, citing the risks of addiction and other gambling harm, the absence of any guarantee that Dutch gambling policy is upheld, and the undermining of channelisation toward licensed providers.

The Ksa drew up its report on August 10, 2026 and invited EOD Code to submit its views by letter and email of September 10, 2026; the company did not respond. In a publication decision of October 6, 2026 under the Open Government Act, the regulator decided to publish the fine decision on its website to warn and protect consumers, to provide transparency about its enforcement and for its preventive effect on other providers, withholding the names of the natural persons involved. The publication decision records that EOD Code also declined the opportunity to give its views on publication.

In its announcement, the Ksa said it opted for a revenue-based fine because it estimates EOD Code earned more from the stakes of Dutch players than standard fine amounts would reflect. It said its enforcement against illegal offerings also involves intensive cooperation with third parties such as payment service providers, hosting companies, banks and large technology companies, and that the ability to pay with cryptocurrency and anonymous payment methods facilitates money laundering.

EOD Code may object to the fine decision within six weeks of its notification; an objection does not suspend the decision. The fine must be paid within six weeks of notification, after which statutory interest is added.