The Kansspelautoriteit (KSA), the Dutch gambling authority, has raised serious concerns over the effectiveness of risk analysis systems used by licensed online gambling operators in the Netherlands. According to a new study, these tools are not functioning properly and fail to deliver the level of protection required under the country’s duty of care regulations.
Risk analysis systems are a key part of the compliance framework for Dutch licensees. Operators must assess the level of risk associated with high-risk games such as online slots and put in place safeguards to limit player harm. However, the regulator found that the systems currently in use provide little additional protection to consumers despite the significant effort and expense required to operate them.
The report, which examined practices across 2024 and 2025, showed that most operators conduct their risk assessments by game category rather than on an individual game basis. This approach saves time and reduces costs, but it also increases the risk that some games are being misclassified at a lower risk level than they should be. Current rules do not specifically require game-by-game analysis, leaving a gap in oversight.
Concerns Over Methodology and Consistency
The KSA highlighted major shortcomings in the tools most widely used in the Netherlands. One of the tools, Asterig, first developed more than a decade ago, delivers consistent outputs but raises questions of reliability and applicability, with criteria and scoring scales that are insufficiently substantiated. Gamgard, the other tool, was described as suitable only for preliminary screening since it evaluates a limited number of risk factors and lacks transparency.
Notably, both systems were designed before the legalisation of the Dutch online gambling market in 2021 and have not been significantly updated since. The regulator pointed out that despite academic concerns raised at the time, no new or improved methodologies have emerged in the market.
The study also found wide variation in outcomes. Even when the same games were analysed, results differed between operators. Sometimes this was the case even when the same external consultancy was used. This lack of consistency means outcomes are not comparable across the market, undermining the regulator’s ability to ensure that player protection standards are met.
Next Steps for Regulation
The KSA concluded that the current system falls short of its objectives. Concerns included unclear definitions of independence when using external analysts and insufficient clarity over the expertise of some consultants. In some cases, it was not evident whether risk assessments had been carried out with adequate independence or by suitably qualified experts.
To address these issues, the KSA confirmed it has begun discussions with the Ministry of Justice and Security to explore reforms. The regulator said its long-term goal is the introduction of a uniform system to assess game risks, ensuring that all operators apply the same methodology and that players receive consistent protection across the market.
