The Dutch Gaming Authority (KSA) has issued revised guidance on deposit limit assessments for online gambling operators, closing loopholes that emerged following a round of compliance inspections that exposed widespread shortcomings across the licensed sector.

The updated framework, published this week, clarifies how operators must evaluate whether players can afford higher deposit limits beyond the statutory thresholds: EUR 300 monthly for ages 18 to 24, and EUR 700 for players 24 and older. These means tests form a cornerstone of the KSA’s duty of care regime introduced in 2024.

Structural Income Only

Here’s where things get specific. Monthly deposit limits must now be calculated exclusively from structural, recurring income. Savings, business assets, home equity, one-off bonuses, and gifts are explicitly prohibited from the assessment.

The KSA acknowledged that earlier wording had inadvertently encouraged operators to factor in non-recurring assets, artificially inflating what players were deemed able to afford. Sample inspections of 20 licensed operators revealed persistent non-compliance and procedural weaknesses. Enforcement actions to date include 10 improvement interviews, three formal warnings, and one binding instruction.

Best and Worst Practices Outlined

The revised guidance now sets out concrete examples of compliant operator behaviour. These include preventing operator-initiated deposit increases above EUR 300 monthly for young adults regardless of declared income, and applying conservative income percentages for lower-earning players. There’s also encouragement for operators to permit a single deposit exceeding limits while a means test is processed, provided a hard cap is enforced afterwards.

Documentation requirements have been tightened considerably. Operators must now retain comprehensive records showing how deposit limits were calculated for each player, with multiple recent payslips or averaged cumulative pay used to establish accurate monthly capacity.

The guidance identifies 13 bad practices to avoid. Among them: unverified self-declarations, treating non-structural assets as income, using highest rather than average payslips, and imposing bonus restrictions for fewer than the mandatory 30 days following a deposit limit intervention.

Market Support Remains Strong

Interestingly, broader industry sentiment continues to favour deposit limits. An October survey of 1,507 respondents found support increased to 82 percent from 76 percent two years prior. The KSA has signalled that focused supervision will continue, with further compliance checks planned to ensure operators adopt the tightened standards.