KSA tightens rules on online gambling deposit means testing

The Dutch Gaming Authority (KSA) has updated its guidance regarding the statutory means test for online gambling players. This follows inspections that revealed ongoing shortcomings despite improvements across the sector. 

The revised guidance clarifies how operators should assess players’ ability to afford higher deposit limits under the Dutch responsible-gaming regime.

Since October 2024, online gambling operators licensed in the Netherlands have been required to conduct a means test whenever players apply to deposit funds over and above the set monthly limits. Those thresholds are, specifically, €300 net for players aged 18 to 24 and €700 for those aged 24 and over. 

The means test is intended to ensure players do not gamble beyond their financial capacity and it forms a key part of the KSA’s “duty of care” framework which was introduced in 2024.

Revised guidance

Published this week, the updated “good and bad practices” document addresses ambiguities in the initial guidance that was issued in February 2025. A significant clarification stipulates that monthly deposit limits must be based exclusively on players’ structural (recurring) income. 

Notably, liquid assets such as savings, business assets, home equity, or one-off payments like bonuses and gifts must not be treated as regular income when determining affordability.

The KSA highlight that previous wording had misled some operators to incorrectly factor in these non-recurring assets, resulting in inflated deposit limits.

Following the initial guidance, the KSA conducted sample checks of 20 licence holders and discovered persistent non-compliance and, in some cases, procedural weaknesses. Enforcement actions taken so far have included 10 improvement interviews, three formal warnings and one binding instruction.

The regulator has indicated that it will maintain focused supervision and perform further oversight to ensure full adoption of the tightened standards.

An original report, first published in October of last year, found that among 1,507 respondents, overall support for the deposit limits increased from 76% two years ago to 82%. 

Recommended practices 

The updated guidance also highlights several examples of positive operator practices. These included prohibiting operator-initiated deposit limit increases above €300 per month for young adults, regardless of their declared income, and applying a lower proportion of net income than the standard 30% when calculating safe recreational spending limits for low-income players. 

Operators are also encouraged to allow a one-off deposit that exceeds a player’s limit before imposing a hard cap of either €300 or €700 if the required means test has not been completed.

In addition, the guidance emphasises the importance of thoroughly documenting how net deposit limits are calculated and retaining this evidence in player records. 

The guidance also recommends using multiple recent payslips or averaging cumulative pay over a given period to establish a player’s monthly income capacity more accurately.

‘Bad practice’

The revised guidance also identifies 13 examples of “bad practice” that operators should avoid. These include accepting unverified income based solely on player self-declarations or other documentation that cannot be reliably traced, as well as imposing bonus restrictions for less than the mandatory 30-day period following a deposit limit intervention. 

The guidance also highlights common calculation errors, such as inflating a player’s net income by using their highest payslip instead of an average.

Other poor practices that were noted include treating liquid assets, a partner’s income, loans or earmarked social benefits as structural income.