The Dutch Gaming Authority (KSA) has revised its guidelines concerning the required means test for online gambling players. This update follows inspections that highlighted ongoing deficiencies within the sector, despite some improvements.
The new guidelines elucidate how operators must evaluate players' financial capability to support higher deposit limits set by the Dutch responsible-gaming framework. As mandated since October 2024, licensed online gambling operators in the Netherlands must perform a means test whenever players wish to deposit amounts exceeding the established monthly limits of €300 for those aged 18 to 24, and €700 for individuals 24 and older.
This means test aims to prevent players from gambling beyond their financial means and is a critical element of the KSA's “duty of care” framework introduced in 2024.
The updated "good and bad practices" document, released this week, addresses ambiguities present in the initial guidance issued in February 2025. A key clarification emphasizes that deposit limits should solely rely on players' structural (recurring) income. Importantly, other financial sources like savings, business assets, home equity, or one-time payments—including bonuses and gifts—should not be considered regular income when assessing affordability.
The KSA pointed out that previous language had inadvertently led some operators to include these non-recurring assets in their calculations, leading to inflated deposit limits. Following the first set of guidelines, the KSA conducted checks on 20 license holders and noted ongoing non-compliance as well as certain procedural weaknesses. So far, the regulatory actions taken have included 10 improvement interviews, three formal warnings, and one binding instruction.
The authority has signaled its intention to maintain stringent oversight to ensure compliance with the updated standards. An initial report from October last year indicated that support for deposit limits among 1,507 respondents had risen from 76% two years ago to 82%.
The updated guidance also spotlights commendable practices among operators, such as forbidding operator-initiated increases to deposit limits beyond €300 per month for young adults, regardless of their declared income. Additionally, operators are encouraged to apply a lower proportion than the standard 30% of net income when calculating safe recreational spending for low-income players, and to permit one-off deposits that surpass a player’s limit before applying the cap of €300 or €700 if the means test is incomplete.
The guidance underscores the necessity of meticulously documenting the methodology behind net deposit limit calculations and preserving this information in player records. It also recommends utilizing multiple recent payslips or averaging cumulative pay over a particular period to more accurately determine a player's monthly income capacity.
Conversely, the guidance delineates 13 examples of "bad practice" for operators to avoid. These include accepting unverifiable income based solely on player self-declarations or unreliable documentation, as well as restricting bonuses for less than the required 30 days following a deposit limit change. Common errors highlighted include inflating a player’s net income by using their highest payslip instead of calculating an average. Furthermore, improper practices identified include treating liquid assets, a partner's income, loans, or designated social benefits as structural income.
