CCBR-Cruks: the measure dividing the Netherlands 

Should people under guardianship or protective administration be automatically barred from gambling? In the Netherlands, the proposal to link the Central Register of Guardianships and Protective Administrations (CCBR) to the gambling exclusion register, Cruks, is sparking debate. 

A protective measure that raises a question of principle 

The aim seems straightforward: to prevent people considered financially vulnerable from exposing themselves to the risks associated with gambling. But does being listed on the CCBR necessarily mean that a person has a gambling problem? 

For Nelis van Steenoven, a guardianship administrator, the answer is clearly no. He opposes the automatic inclusion in Cruks of all those listed in the CCBR. In his view, such a measure would transform a register created for a specific purpose into a general tool for gambling exclusion, without taking into account the individual circumstances of those concerned. 

The CCBR is not a register designed to identify people with problematic gambling behaviour. Some people are listed on it, in particular, due to physical or mental health conditions. Being listed on this register does not, therefore, in itself, allow one to determine a person’s gambling habits. 

‘The proposal overlooks a crucial point: not everyone listed in this register has a gambling problem,’ says Nelis van Steenoven. 

Why a link between the CCBR and Cruks is being considered 

The proposal put forward by the chairman of the Ksa, Michel Groothuizen, is based on a different rationale. It aims, above all, to strengthen the protection of a group considered to be particularly vulnerable. 

‘By linking the CCBR directly and fully to Cruks, we are offering optimal protection to an extremely vulnerable group,’ he stated. 

According to him, administrators and trustees are calling for such a measure. In practice, linking the registers would make exclusion much more systematic, as registration with the CCBR could lead to registration with Cruks. 

This approach forms part of a wider debate on the monitoring of vulnerable gamblers in the Netherlands. 

Three years before the publication of this position statement by Nelis van Steenoven, Fair Play Online had announced that it would not accept players listed on the central register of guardianships and administrations. The company presented this check as part of its commitment to responsible gambling. 

Gambling limits also place the CCBR at the centre of the debate 

The CCBR also features in another initiative concerning Dutch gambling policy. 

In June 2026, State Secretary Claudia van Bruggen presented proposals regarding overall gambling limits. As part of this, she wants a check to be carried out whenever a person requests an increase to their limit. The aim would be to determine whether that person is under administration or guardianship before authorising a change to the limit in question. 

For advocates of stricter controls, the information contained in the CCBR can serve as an indicator of vulnerability. For Nelis van Steenoven, however, this approach risks treating very different situations in the same way. 

A listing on the CCBR does not reveal a gambler’s behaviour 

The protection officer’s main argument is that the inclusion of a person in the CCBR provides no specific information about their relationship with gambling. The register serves a specific purpose and does not constitute a database of people with a gambling problem. Applying an automatic exclusion on this basis alone would therefore, in his view, amount to imposing a restriction without verifying the existence of the risk that this restriction is intended to prevent. 

Nelis van Steenoven: 

‘At first glance, this seems logical, but in reality, it is a significant and disproportionate intervention that further alienates people from society,’ he argues. 

His reasoning is also based on a previous decision by the Dutch Human Rights Board. According to the evidence he cites, a difference in treatment based on a measure introduced for medical reasons may constitute prohibited discrimination. 

An automatic link between the CCBR and Cruks would therefore also affect people placed under protection for such reasons, even where there is no evidence to suggest they have problems with gambling. 

Is automatic exclusion really necessary? 

Nelis van Steenoven puts forward another argument: administrators already have the option of having a person registered in Cruks when they consider this necessary for their client. In his view, the existence of this option undermines the justification for a blanket exclusion of all persons registered with the CCBR. 

Michel Groothuizen advocates a comprehensive approach to protecting a population deemed particularly vulnerable. Nelis van Steenoven favours a more individualised assessment and rejects the idea that a legal protection measure should automatically be equated with an inability to participate in gambling. 

The difference between the two positions therefore concerns both the means employed and the objective sought. 

For Nelis van Steenoven, a protective measure should enable those concerned to participate in social life as much as possible. He believes that an administrator should even be able to authorise a person to gamble with a limited sum where their circumstances permit. 

‘As an administrator, you should also be able to authorise someone to gamble with a small sum, just like anyone else,’ he states. 

His reasoning is therefore not to deny the risks of gambling. Rather, he advocates the possibility of tailoring restrictions to each individual situation, rather than assuming that anyone registered with the CCBR must necessarily be excluded. 

This position echoes a theme he had already put forward in a previous opinion piece: the importance of autonomy for people with disabilities. 

Can protection become a new form of exclusion? 

Nelis van Steenoven believes that people subject to a protective measure already face difficulties linked to their inclusion in the CCBR. 

In particular, he claims that credit reference agencies use the register to issue negative reports on people subject to protective measures. 

He fears that a link with Cruks would add a further automatic consequence to inclusion in the CCBR.  

His objection goes beyond the issue of casinos. It concerns the principle that a person under administration or guardianship could gradually be subject to various restrictions without an individual assessment of their situation. In his view, the state does not resolve the problem of the exclusion of people with physical, intellectual or mental vulnerabilities by imposing new general restrictions on them.