Dutch Gambling Regulator Upholds ComeOn Operator’s Duty-of-Care Fine

The Netherlands Gambling Authority has upheld a €750,000 player-protection fine against ComeOn operator Tulipa Ent Limited after rejecting the company’s objections to both the sanction and its publication. The regulator disclosed the October 20, 2026 ruling and supporting records on November 10, 2026.

The board’s objection decision leaves the December 16, 2025 fine and publication decisions unchanged. The advisory opinion, issued on October 3, 2026, records that the original decisions were published on January 13, 2026; Tulipa objected on January 29, 2026 and supplemented its grounds on March 10, 2026. The committee recommended rejecting every objection, and the board adopted that advice. The ruling remains open to appeal in the administrative court.

How the Monitoring Case Was Built

Malta-based Tulipa offers remote gambling in the Netherlands through comeon.nl and ComeOn-branded apps under a license running from September 6, 2022 through September 5, 2027. The original sanction decision identified breaches from December 19, 2023 through August 29, 2024 involving ten young-adult players, citing inadequate analysis of gambling behavior, unsuitable or late interventions and failures to conduct required personal interviews. The duty of care requires licensees to take measures needed to prevent excessive gambling and addiction as far as possible.

The investigation focused on players aged 18 to 24, a group the regulator says needs particular protection because of its vulnerability to risky gambling. Investigators used control-database information to select the young adults with the largest losses from January 1, 2024 through June 30, 2024, while also identifying frequent playing days and nighttime gambling before requesting their files.

Tulipa’s software calculated a daily risk score for each player and generated automatic reports at preset thresholds, including €1,000 in gross deposits within 24 hours or a €3,000 net loss within seven days. The regulator found that those triggers could come too late for young adults. High limits, repeated deposits, nighttime play, failed deposits and substantial losses had to be considered together; staying within limits chosen by the player did not remove the obligation to act.

One anonymized file shows the speed of the losses at issue. A young adult made four deposits in under 15 minutes totaling more than €16,000 and lost the full amount within an hour; the account had a €20,000 daily deposit limit and an eight-hour daily playing-time limit. In another file, a player deposited more than €15,000 over approximately six hours of nearly continuous overnight gambling and lost almost all of it. Deposit and product blocks and permanent account closure followed on the second playing day, after that loss.

Why Tulipa’s Objections Failed

Tulipa argued that its daily updated risk profiles and manual or automated reviews were sufficient, that the rules then in force set no analysis deadline, and that the regulator had retroactively applied requirements introduced in October 2024. The advisory committee responded that continuous monitoring and timely analysis and intervention were already required. It said the later wording had been used illustratively, not as the rule against which the earlier conduct was judged, and that the statutory list of warning signs was not exhaustive.

The committee found generic awareness emails insufficiently tailored to a player’s age, behavior, warning signs and response to earlier measures. Telephone calls and account or deposit blocks often came days or weeks too late, after young adults had lost thousands of euros.

Tulipa also argued that financial-position checks belonged only in a personal interview and that its stepped intervention model required lighter measures first. The committee said serious warning signs could justify an immediate personal interview, while insight into a player’s financial position could be necessary earlier to assess whether the gambling was affordable. It accepted that automatic deposit blocks were not mandatory at the time, but found that this did not permit operators to delay suitable interventions.

On the penalty, Tulipa sought a €350,000 starting amount rather than €500,000 and compared its case with advertising sanctions and penalties based on gross gaming revenue. The committee said the higher starting amount was available for very serious duty-of-care breaches, rejected the comparisons and concluded that the fine was proportionate. It also found that Tulipa had not substantiated its asserted commercial and reputational damage from publication with concrete evidence.

A separate publication decision keeps the objection ruling on the regulator’s website. The authority said disclosure allows consumers to examine its reconsideration of the sanction and the reasoning behind it, while also providing transparency about its enforcement work.

For any court challenge, the central question is whether Tulipa’s monitoring and stepped interventions met obligations that, in the committee’s assessment, already required continuous oversight and earlier, player-specific action when serious warning signs accumulated.