For several months now, the debate has been raging in the Netherlands over the introduction of common monthly deposit limits for all online gambling operators.While the measure aims to provide better protection for players, it does raise some major concerns. Privacy issues, technical challenges and threats to the channelling of legal gambling are all serious obstacles to its implementation.
Since October 2024, the Netherlands has applied a monthly deposit limit per operator. This segmented approach, €700 for adults and €300 for young people aged 18 to 23, has proved effective. But the government wants to go further: an overall limit that is interoperable between all operators.
Once a player has reached the limit with one operator, they will be blocked with all.
Secretary of State Struycken spoke on this subject on Radio-1’s NPO programme Langs de Lijn en Omstreken. Although he fully supports the project, he said that a global limit would pose a major challenge and could conflict with the General Data Protection Regulation (GDPR).
A potential breach of the GDPR regulation
Compliance with the GDPR has been mandatory in both the Netherlands and Belgium since 2018.
The introduction of a global limit system requires the centralised collection of sensitive personal data: identifiers, financial behaviour, deposit information. These requirements conflict with several principles of the General Data Protection Regulation (GDPR):
- Transparency: players must understand who is processing their data and why. In a system shared between several operators and a central authority, this clarity is difficult to guarantee.
- Data minimisation: only strictly necessary information should be collected. However, cross-sector surveillance implies systematic data collection, including for gamblers who do not display problematic behaviour.
- Retention period: data should not be stored indefinitely.However, a system of this kind requires financial and behavioural data to be kept for a long time.
The fundamental guarantees of privacy could be compromised by such invasive surveillance, in the name of a legitimate but perhaps disproportionate objective.
Technical challenges
While the legal hurdles are surmountable, the technical feasibility of a centralised system poses problems for a number of reasons:
- Real-time exchange: data must be synchronised instantaneously between operators and the regulator to avoid any overruns. A difference of a few seconds can distort the limits and lead to unfairness for players.
- Unique identification: the system must recognise each player uniquely, which implies a common identifier for all operators. This could be the national identification number, but that would multiply the risks in the event of piracy.
- Extreme IT security: the concentration of data in a single database makes it a major target for cybercriminals. An infallible system therefore needs to be put in place.
- Software compatibility: not all operators use the same systems. Imposing a common protocol requires time and resources, and exposes small players to de facto exclusion.
- Error management: if a player is wrongly blocked, they need to be able to understand why and correct the error quickly. But automated systems are often opaque.
Threat to channelling towards legal offers
The Kansspelautoriteit (Ksa) report of February 2025 reveals that the number of players is channelled correctly (91% play on legal sites), but that the financial volumes are worrying: almost 50% of the money wagered is channelled into the black market.
And the figures are getting worse. According to the Keurmerk Verantwoorde Affiliates (KVA):
- In October 2024, 19 illegal sites attracted 172,000 monthly visitors on queries such as ‘casino without Cruks’.
- By February 2025, this figure had risen to over 410,000.
- In March 2025, overall traffic to illegal sites exceeded one million monthly visits.
These campaigns specifically target players frustrated by the limits imposed in the legal circuit. If the restrictions become too onerous, even more of these players will flee to unregulated platforms, often located abroad, where consumer protection is non-existent.
An overall limit in Belgium too?
The issue of an overall limit has also been raised in Belgium. According to the Flemish centre for expertise on alcohol and other drugs (VAD), an overall limit is needed so that players can no longer create accounts with different operators in order to play more than the €200 weekly limit. However, iGaming experts claim that this would be the best way to drive even more players into illegal gambling.If Belgium imposes an overall limit, it will face the same difficulties as the Netherlands. No such decision has yet been taken.