The Ministry of Justice and Security previewed in late-2024 communications the 2025 Wet Kansspelen op afstand policy review agenda. The review is the next major framework adjustment opportunity following the 2023 advertising-standards revision, and the agenda items that the Ministry has previewed are methodologically substantive in their own right and informative about the longer-term framework direction the Ministry appears to be considering.
The previewed agenda items include the cross-border unlicensed market problem, the responsible-gaming framework evaluation methodology, the advertising-standards trajectory, the operator-licensing renewal criteria, and the supervisor-resource framework. Each item is methodologically substantial, and the policy choices the review produces will be consequential for the framework operational reality through the next several years.
The cross-border unlicensed agenda
The cross-border unlicensed market problem has been on the policy agenda since the framework opening and has not been resolved through the available enforcement mechanism alone. The 2025 review is expected to engage with policy approaches beyond licensed-estate enforcement, including payment-channel intervention frameworks, search-environment engagement mechanisms, and affiliate-publisher regulatory approaches.
The payment-channel intervention question is the most-substantively-developed of the available policy approaches. The Ministry has been engaged with the financial-services supervisor on payment-channel framework development for the unlicensed cross-border problem, with the resulting work producing a partially-developed approach that the review process is expected to formalize. The substantive details remain under development, but the policy direction appears to be toward regulatory engagement with the payment-services side of the unlicensed-operator infrastructure rather than primary reliance on operator-side enforcement alone.
The search-environment engagement is a second area where policy development has been preliminary but is expected to advance through the review. The licensed-operator framework constrains licensed Dutch operators from competing for some search-traffic categories that the unlicensed alternatives are not equivalently constrained on, and the resulting asymmetry produces structural search-visibility advantages for the unlicensed operators. The review is expected to address the asymmetry through approaches that may include search-engine engagement mechanisms or licensed-operator framework adjustments that produce more equivalent competitive conditions.
The responsible-gaming evaluation methodology question
The responsible-gaming framework — Cruks self-exclusion, advertising-standards, operator-side harm-detection protocols — has been operationally successful at the implementation level but methodologically less established at the population-outcomes level. The available evidence base on whether the framework is producing harm-reduction at the population level rather than simply at the implementation level is fragmentary and methodologically uneven.
The 2025 review is expected to engage with the framework-evaluation methodology question. The substantive issues include what data infrastructure the evaluation requires, what research methodology is appropriate for the framework-evaluation question, and how the resulting evaluation evidence should be integrated into the policy-development process. The methodological work has been preliminarily addressed by the supervisory authority and by independent research bodies, but a comprehensive evaluation framework has not been operationally established.
The implications of the evaluation question are policy-substantive. The framework-effectiveness conclusion is consequential for the policy direction the framework should take, including how the friction between consumer-protection objectives and consumer-autonomy considerations should be calibrated and how the framework restrictions should be tightened or loosened in response to the empirical record. The review is unlikely to produce a comprehensive evaluation outcome on this cycle, but is expected to advance the methodological development substantially.
The advertising-standards continuation
The advertising-standards framework has been the most-actively-adjusted policy area through the framework operational period, with successive tightening through the 2022, 2023, and 2024 policy cycles. The 2025 review is expected to continue the trajectory, with the substantive issues including placement-frequency further constraints, content-element further restrictions, and audience-targeting framework development.
The Reclame Code voor Online Kansspelen has been the principal vehicle for the advertising-standards adjustment, with the Code Commission and the supervisory authority producing successive policy revisions through the operational period. The 2025 review is expected to engage with the framework architecture itself, with the policy question of whether the Code-based framework should be supplemented by primary legislation on specific advertising-standards elements being part of the previewed agenda.
The friction-asymmetry implications of further advertising-standards tightening are part of the policy consideration. The licensed-operator framework restrictions produce competitive disadvantage relative to the unlicensed cross-border alternatives that are not subject to equivalent constraints. The asymmetry implications are likely to influence the review outcomes, with the policy challenge being how to advance the harm-reduction objectives of advertising-standards tightening without producing unintended migration of consumer activity to the less-protected unlicensed alternatives.
The operator-licensing renewal question
The original Wet Kansspelen op afstand licenses were issued for five-year terms, with the renewal cycle approaching for the early-issued licenses. The 2025 review is expected to address the renewal-criteria framework — what supervisory-record threshold the renewal requires, what compliance-history considerations apply, and what the renewal-decision methodology should consist of in operational terms.
The substantive policy issues include how the supervisor-record performance of licensed operators through the operational period should influence renewal decisions, how the framework-development trajectory through successive policy revisions should affect renewal terms, and how the cross-border consideration — the relationship between licensed operators and any cross-border activity by associated entities — should be addressed in the renewal-evaluation framework.
The renewal-cycle is methodologically substantive for the framework future. The renewal-criteria framework establishes how the supervisory authority assesses operator-side compliance with the framework standards over the operational period, and the criteria choices have consequential implications for the operator-side incentive structure through the next license cycle.
The supervisor-resource framework
The Kansspelautoriteit has substantively expanded its operational capacity through the framework period, but the resource base required to sustain the supervisory activity has been a continuing policy concern. The 2025 review is expected to engage with the supervisor-resource framework — how the supervisory budget should be structured, how the supervised-operator funding contribution should be calibrated, and how the resource framework should respond to the increasing complexity of the supervisory work.
The substantive policy issues include the multi-year resource-planning framework, the relationship between the operational supervisory activity and the policy-development work the authority engages in, and the institutional-capacity development that sustained framework operation requires. The resource framework is methodologically substantive because the supervisory effectiveness depends substantively on the available resource base, and the framework-effectiveness conclusions of the review depend in part on whether the supervisor-resource considerations have been adequately addressed.
What the review trajectory implies for the framework direction
The 2025 review will not produce comprehensive resolutions of all the previewed agenda items, but is expected to advance the framework development substantively across the agenda areas. The cross-border unlicensed problem is likely to receive the most-substantive policy development through the review cycle, with the resulting policy approaches likely to extend beyond licensed-operator enforcement into payment-channel and search-environment engagement mechanisms.
The responsible-gaming evaluation methodology development is likely to receive incremental rather than comprehensive policy attention. The methodological work is substantial and the comprehensive evaluation framework will require sustained development beyond a single review cycle. The 2025 review is expected to advance the methodological infrastructure development that subsequent reviews can build on.
The advertising-standards trajectory is likely to continue the tightening direction that successive review cycles have established. The substantive policy question is whether the tightening will be incremental from the current framework position or whether the review will produce a more substantive framework architecture change. The available previews suggest incremental tightening is more likely than architecture revision, but the substantive details will emerge through the formal consultation process.
