KSA orders Endorphina to prevent games reaching illegal Dutch gambling sites

The Kansspelautoriteit (KSA), the Netherlands Gambling Authority, on 2 November published its 19 October binding instruction against Endorphina Limited in Malta and Endorphina Ltd. in Cyprus. It found that the companies had not taken adequate measures to prevent their games being offered to Dutch players through gambling websites without a Dutch licence, and ordered them to counter that availability.

The action is directed at a game supplier rather than the operators accepting wagers. Under Article 1(1)(b) of the Betting and Gaming Act (Wok), the KSA treats promoting participation in an unlicensed game as prohibited. Its decision says supplying games to an operator is permitted only where that operator holds a KSA licence. Article 34n allows the KSA to issue a binding instruction to intermediaries providing essential components of a remote gambling system without organising the gambling themselves.

The KSA’s evidence

Between 12 January and 19 February 2026, KSA inspectors using Dutch IP addresses participated in Endorphina games on unlicensed websites. The decision documents 15 instances, including:

- Hell Hot 100 on Starzino and Amonbet;
- Royal X-mass on Holyluck;
- Bad Santa on Chacha.bet;
- Wild Love on Luckygem;
- Thunder Crown on Spinstar.bet; and
- Fortune Snake on Justbit.io.

Other games included Cockroach Fortune, 3 Royal Dracos, Sushi, Royal Xmass 2 Dice, Lucky Streak 3 and Lucky Cloverland. The KSA said it observed no technical measures preventing people in the Netherlands from accessing the games.

The websites were among 13 domains on which the KSA found gambling offered without a Dutch licence. It shared those findings with Endorphina on 15 April. The decision also records follow-up checks on 8, 10 and 17 June across 19 unlicensed gambling websites, including Betspino, Luckygem, Boomerang, Starzino, Chacha, Amonbet, Trueluck, Booms and Justbit.

The KSA’s finding is that continuing to make Endorphina games available in that setting promoted unlicensed gambling. The published decision does not frame the issue as a failure by Endorphina to hold a Dutch gambling licence. Instead, it applies the intermediary rule to the company’s role in supplying game content to operators that lacked one.

A signal to suppliers and intermediaries

The instruction is a remedial supervisory measure, not a monetary penalty. Its importance is the KSA’s stated basis for using Article 34n: a supplier can be addressed where its services form an essential part of the system through which illegal online gambling reaches Dutch consumers.

Atlas reads the order as a warning that game studios and other gambling technology providers cannot treat downstream licensing as solely the operator’s responsibility once they receive signals that their products remain available in the Netherlands. The practical control question is whether suppliers can identify the websites distributing their content, respond to regulator notifications and prevent further Dutch access. The KSA’s order requires an outcome, namely that Endorphina’s games are not available to Dutch players through unlicensed sites, rather than merely an internal review.

The KSA’s separate publication decision says publication serves consumer protection and preventive enforcement. The authority said games appearing on both licensed and unlicensed websites could give consumers the impression that an unlicensed website was reliable. It also expressly cited the need to set standards for and warn other game suppliers and intermediaries.

That approach sits alongside recent action against the operators of two domains in the Endorphina investigation. On 22 October, the KSA ordered JACO V.I.P. to stop unlicensed gambling through Spinstar, while on 15 September it ordered Virtual Connect to stop unlicensed gambling through Luckygem. On the same 22 October enforcement date, the KSA fined EOD Code SRL €37.25m for offering unlicensed online gambling in the Netherlands. The Endorphina instruction shows the authority pursuing the content supply chain as well as the gambling operators themselves.

The KSA’s page states that an objection may be lodged. The publication decision sets a six-week period from notification and says an objection does not suspend that decision.