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He argues that some lawyers and licensees believe the Commission’s presentation of cases is detached from the operational reality but feel they have little option other than to accept the “regulator’s truth” when settling.

“The Commission’s approach to reporting may well create the inaccurate impression that the industry is inherently non-compliant,” he adds. A more balanced account might place failures alongside the majority of licensees that pass assessments or lead on customer wellbeing, although Waugh considers such a shift unlikely.

The “too easy to get a licence” argument doesn’t necessarily hold up to scrutiny, to be fair. Andrew Bentley, co-founder and CEO of regulatory technology startup LiSense, is one who rejects the suggestion.

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Dahms highlighted the significant dangers unlicensed operators pose to player protection and the overall integrity of the licensed market. He cited the absence of controls such as deposit limits, identity verification and player suspension tools. 

He also called for continued rigorous enforcement efforts alongside strict regulation to safeguard consumers, adding: “Anyone who wants to strengthen player protection must therefore consistently crack down on illegal services and strengthen legal ones.”

The DSWV said the findings should prompt a thorough reassessment of official black market size estimates in Germany.

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In a written response published in January 2026, Arno Rutte, the state secretary at the time acknowledged that enforcement against such sites remained limited, particularly for domains not registered under the .nl extension.

According to KVA, KT van Bruggen, the current state secretary for Justice and Security, has pointed out the urgency of implementing effective countermeasures to limit access to such illegal platforms.

Last week a committee made up of MPs from across the Netherlands’ political spectrum also raised concerns around the role of Meta and Google in supporting the black market.