NETHERLANDS Law and Practice Contributed by: Alan Littler, Justin Franssen and Chris Adriaansz, Franssen Tolboom
make use of this exception to the default position. As such, the applications of operators with a (previ- ous) presence on the Dutch market submitted after 31 March 2022 will – in principle – be rejected. The reliability of these operators will not be considered “beyond any doubt”. The NGA will also take into account the unlicensed presence of persons and entities surrounding the licence applicant. Whether an unlicensed presence of these persons will lead to rejection is something that cannot be answered in general terms. Probity Screening The second step consists of a test based on the Pub- lic Administration (Probity Screening) Act ( De Wet Bibob , or the “Bibob Act”). This test allows the NGA to assess: • whether there is a danger that the licence will be used to utilise monetary benefits obtained or obtainable from criminal acts; and • whether a criminal act has been committed in order to obtain the licence. Where the NGA deems necessary, and in specific situ- ations, it will ask for advice from the Bibob Agency ( Landelijk Bureau Bibob ), which specialises in integrity assessments and in providing advice to government authorities. Integrity Assessment for Land-Based Slot- Machine and Charity Lottery Licences The above-mentioned integrity assessment for remote gambling applicants does not apply mutatis mutan- dis to land-based slot-machine (exploitation) licence applications and charity lottery licence applications. However, in practice, the NGA’s integrity assessment for these licences recently became virtually identical to the assessment for remote gambling applicants – with some slight differences in scope. The NGA’s investigation will include an assessment of the appli- cant’s: • finances; • antecedents; • organisational structure; and
• business relationships with other natural or legal persons. Furthermore, applicants for land-based slot-machine and charity lottery licences could also be subject to a test based on the Public Administration (Probity Screening) Act. On 3 October 2022, the NGA pub- lished its policy rules on probity screening for land- based slot-machine applicants. 4.7 Application Timing The NGA has six months to assess a remote gambling licence application. This period can be extended by another six months. Internally, the NGA divided the licensing process into two phases: • information gathering; and • decision-making. Licence applications for slot machines, incidental lot- teries and charity lotteries must be completed within eight weeks. This period can be extended depend- ing on the (additional) information required from the applicant. 4.8 Application Fees Fees for slot machines consist of the fees for prem- ises and for exploitation licences. In accordance with applicable legislation, premises licences are set by individual municipalities at a maximum of EUR22.50 (plus EUR34 per slot machine) per year. The exploita- tion licence awarded by the NGA is subject to a one- off fee of EUR1,815.12 and an annual gambling levy per player seat. In 2025, this annual fee was EUR136 per player seat. Fees for incidental charity lottery licences depend on the total amount of the prizes that can be won: • prizes totalling an amount of more than EUR4,500 and up to EUR50,000 are subject to a fee of EUR500; • prizes totalling an amount of more than EUR50,000 and up to EUR500,000 are subject to a fee of EUR4,100; and • prizes totalling an amount of more than EUR500,000 are subject to a fee of EUR24,000.
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