NETHERLANDS Trends and Developments Contributed by: Alan Littler, Franssen Tolboom
the prohibition on promoting and otherwise facilitat- ing unlicensed games of chance. Unsurprisingly, the prohibition on promoting includes unlicensed remote offerings which are available in the Netherlands, and the NGA’s website provides many examples of enforcement measures being served against affiliates, and lately influencers, who promote the offerings of remote providers lacking an NGA licence. The prohibition on promoting also extends to offer- ings that are available to residents of the Netherlands but where the physical gambling offering is based in another jurisdiction. This explains the absence of advertising in the Netherlands for casinos or lotteries in neighbouring Belgium and Germany, for example. Furthermore, as of 1 July 2025, locally licensed remote gambling operators are prohibited from engaging in sponsorship activities given the prohibition on untar- geted advertising for remote gambling. It is arguable that this still leaves scope for some sponsorship activ- ities to take place within the narrow contours avail- able for online targeted advertising. Such contours do not, in any case, enable an operator to allow a sports team to compete with the operator’s logo visible in an offline setting (eg, on the football players’ jerseys). To be clear, the ban on untargeted advertising, and thus making sponsorship deals visible in an offline envi- ronment, only applies to licensed operators. A sports team taking part in an event in the Netherlands whilst being sponsored by a locally unlicensed operator, which is present on the Dutch market, would breach the ban on promoting unlicensed games of chance. In the summer of 2025, the NGA took the position that the prohibition on promoting unlicensed games of chance also includes instances where no underlying gambling offer is available in the Netherlands. Shortly before the 2025 Dutch F1 Grand Prix in Zandvoort, the NGA issued a press release on 21 August stating that it is prohibited for sports teams to promote gam- bling operators that do not have a Dutch licence, and that such expressions for locally unlicensed opera- tors amounts to promoting illegal gambling. The same issue arose in September, when Inter Milan played against Ajax in Amsterdam, as part of the Champi- ons League, whilst appearing with “Betsson.sport” on their jerseys. The NGA let it be known, following the match, that they were not amused, and that they
had previously advised the Dutch Football Association (KNVB) that this would not be permitted as it would amount to promoting illegal gambling. Consequently, the NGA was considering potential next steps in this particular regard. (CasinoNieuws, Ksa “zeer ontstemd” over Betsson-logo op shirt Inter Milan (NGA “very dis- pleased” with Betsson logo on Inter Milan jersey), 18 September 2025 (updated on 25 September); and Mogelijke boete voor Inter Milan; club is zich van geen kwaad bewust (Possible fine for Inter Milan; club is not aware of any wrongdoing), 22 September 2025 (updated on 2 October).) This is in stark contrast to 2024 when, ahead of the F1 Grand Prix, the NGA stated in a CasinoNieuws article of 27 August 2024, that under the current legislation it was not possible to initiate enforcement measures because there needed to be an offer in the Neth- erlands. The law did not change in the intervening twelve months. The 2025 position is also in stark contrast with all interpretations to date, which demonstrate that the law seeks to prevent the promotion of unlicensed gambling which is available in, or otherwise to those in, the Netherlands. Further, the NGA equates a locally unlicensed operator with illegal gambling. Yet noth- ing is further from the truth should there be no actual underlying gambling offer. The mere fact that a logo is visible does not entail that there is such an offer. Global events have global audiences, and whilst locally licensed operators are unable to engage in sponsorship activities which are visible to specta- tors at a game or on TV, those who are not present in the Netherlands, and do not have any activities in the jurisdiction, are not prohibited from doing so under the law as it stands. Whilst this might not sit comfortably with restrictions on gambling advertising (including sponsorship) as applicable to licensed operators, the NGA is overstepping the mark through equating all locally unlicensed operators with illegal operators. Not all operators without a licence from the Netherlands are to be found on the Dutch black market. Should the NGA believe that its latest position on the matter is tenable before a court of law, then it may well ignite further action during 2026.
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