Gambling Club spoke to Steven Gillis Vrolijk, representative of the Keurmerk Verantwoorde Affiliates (KVA) in the Netherlands. In a world where online gambling is receiving more and more attention – as well as more regulation – the need for transparency and responsible behaviour is growing. KVA wants to make a difference in this respect.
In the interview below, Vrolijk answers questions about the origins, working methods and future ambitions of the quality mark.
What prompted you to establish the Keurmerk Verantwoorde Affiliates?
The Keurmerk Verantwoorde Affiliates was initially set up to create more confidence among licence holders and the Kansspelautoriteit. There were – and are – many affiliates that do not comply well with the rules. At the same time, we spoke to many affiliates who do value this and consider it important to comply with laws and regulations.
We set up this quality mark for those parties: to strengthen their position and show that they operate responsibly. Currently, we are also increasingly focusing the hallmark on consumers, so that they can distinguish between reliable and unreliable affiliates.
What specifically does “responsible affiliate behaviour” mean to you?
To me, responsible affiliate behaviour means that an affiliate thinks carefully about exactly what gambling entails and the risks involved – and incorporates that into the way content is presented. That means, for example, including regular warnings, neat and transparent content design, and no misleading information.
For that, we have created the KVA Code. Basically, responsible affiliate behaviour means complying with that code.
How do you make sure affiliates really comply?
We do so by conducting extensive compliance audits every year. In doing so, we draw up a full report with action points and advice. We also carry out spot checks, verifying whether affiliate websites are still operating according to the rules.
For this purpose, we have our own compliance team at KVA. This team has knowledge of the Remote Gaming Act, of the content and operation of online games of chance, and of what an affiliate may or may not do. This allows us to provide targeted and expert supervision.
What do you think makes the KVA different from other initiatives in the industry?
The KVA is actually a unique initiative. Before the creation of the KVA, there was no quality mark specifically for affiliates in the gaming sector. We also distinguish ourselves from other initiatives through our active and transparent approach.
We regularly publish reports showing how bad things are in the illegal sector. Those reports contribute to awareness and enforcement, and underline the importance of responsible affiliate marketing.
What mistakes do you see most often among affiliates who are not (yet) affiliated?
A common mistake is selling backlinks to illegal parties. This is absolutely not allowed with KVA members and is actively monitored. Furthermore, we regularly see that content at non-affiliated affiliates is less carefully designed – both in terms of content and compliance.
At the same time, I must also honestly say that there are certainly legal affiliates who are not yet KVA members, but still operate in a decent way. In that sense, the quality mark is also a help tool: it helps affiliates comply with laws and regulations. Because unless you have extensive knowledge of all legal requirements yourself, it is difficult to stay compliant with everything. The KVA then offers support, advice and concrete action points.
Legislation around gaming changes regularly. How does the KVA stay current?
The KVA can’t help but stay current, as many of the changing regulations directly affect advertising – and therefore affiliates as well. When those regulations change, we have to update our code of conduct to stay in line with the law.
Following new legislation and implementing those changes in our own standards is thus an ongoing part of our work.
What does your verification process look like for member websites?
The verification process for affiliated websites is quite extensive. What I would recommend is to take a look at the following page from CasinoNieuws.nl (in Dutch). They have been publishing all KVA reports for years. There you can see exactly what our audit process looks like, which components are assessed and how detailed our methodology is. It gives a good idea of the thoroughness and transparency with which we work.
What do you do if an affiliate violates the KVA Code?
An affiliate who violates the KVA code will initially receive a warning. This is because it is not always a conscious violation. We then give them a chance to rectify it. But if there are no improvements, we can take stronger measures
The agreement with our members includes a penalty clause, which we can apply in serious or repeated cases. And in extreme cases, we terminate their membership and expel them.
What do you think is the biggest challenge in enforcing responsible promotion?
The biggest challenge is that an awful lot of pages are published. Affiliate websites often contain hundreds to thousands of pages. It is up to us to navigate through them properly and carry out targeted checks. It is also important for affiliates to understand that an advice or comment we give on one specific page usually applies to all similar content on their platform.
That awareness and translation – from individual feedback to structural application – is essential for effective enforcement.
There has been criticism of the ban on untargeted advertising. How do you view it?
We understand that this criticism is there. A licence holder invests significantly in obtaining a licence, and then the opportunities to make themselves known are quite limited. In that sense, it is understandable that there is frustration about the ban on untargeted advertising. At the same time, we must also keep in mind the social importance of protecting vulnerable target groups. So it remains a search for the right balance.
What role does the KVA play in protecting vulnerable target groups, such as young people?
The KVA is actively engaged in protecting vulnerable target groups, including young people and players registered in CRUKS. For instance, we have launched warning campaigns specifically targeting CRUKS players. We have also published research reports showing that minors could deposit and play at illegal online casinos with a Dutch youth account.
One of those investigations even made the national news (in Dutch). In this way, we try to contribute to better protection of vulnerable players with concrete actions and facts.
How important is transparency for consumer-affiliate trust?
A very good question – and also something we are actively working on at the moment. The KVA was initially set up to build trust with licence holders and the Kansspelautoriteit. But with the illegal sector growing so fast, we find that it is becoming increasingly confusing for consumers. That is why we are now focusing more explicitly on consumers.
The aim is that consumers will soon be able to easily recognise whether they are dealing with a reliable affiliate. For example, because they see the KVA seal of approval on a comparison website, can check that logo on the official KVA website, and then click through to legal casinos with peace of mind. So transparency is essential for consumer trust – and a key focus for us.
You also operate internationally through QMRA. What are the main differences by country?
Indeed, we also work internationally. The main differences per country lie mainly in the role the label fulfils. In strictly regulated countries, the quality mark serves mainly to inspire confidence among regulators and licence holders. In less strictly regulated countries, members see the trustmark as a way to show website visitors that they are trustworthy.
In yet other countries, the hallmark is mainly of practical importance, for example as a supporting certificate to be allowed to place ads on platforms like Meta or Google.
Do you see the KVA as something that was created mainly out of necessity, or idealism?
The KVA falls under a private limited company, namely XY Legal Solutions B.V. The same applies to our international hallmark. This makes it formally a commercial project. At the same time, revenues are unfortunately still quite low, so we try to do as much work as possible with limited resources – which is sometimes challenging. But the label was certainly not born out of commercial considerations.
It was born out of the need of trusted affiliates who were annoyed by being lumped together with parties that did not follow the rules at all. So you could say that idealism played an important role in the creation of the KVA.
Where do you hope the KVA will be in five years?
We hope that in five years, the KVA will be a clear and recognisable standard for consumers. That people can tell from the hallmark: this party is reliable, this is legal. We also hope that the cooperation with the Kansspelautoriteit will be expanded even further than it is now.
We see the KVA as an ongoing initiative – and more broadly, affiliate labels as a structural part of the industry. Ultimately, our ambition is for our company to become the compliance standard for affiliates, also internationally.
To conclude
The interview with Steven Gillis Vrolijk makes it clear that the KVA is more than a tick behind compliance. It is a vision of how affiliate marketing in gaming can be shaped to be sustainable and socially responsible.
In an industry where grey areas and quick profits still too often dominate, the KVA offers structure, enforcement and idealism. And above all: a concrete step towards a safer and more transparent gaming market – for all involved.