KSA introduces ‘exit plan’ requirement for online gambling licencees

Summary

Dutch gambling regulator Kansspelautoriteit (KSA) will require all applicants for a remote gambling licence to include an “exit plan” explaining how they would withdraw from the Netherlands if they do not renew their licence. The rule, part of several policy amendments, comes into effect on 1 January 2026 and applies to both new applicants and firms reapplying for renewal.

Operators must submit the exit plan with their licence application and also provide a document describing how they will notify the regulator of timely changes to policies and operations. KSA additionally requires a risk analysis addressing anti‑money laundering (AML) and counter‑terrorist financing (CTF) obligations.

Non‑compliance may lead to application rejection, even for businesses that previously held a Dutch licence. The move arrives as early licences — issued around the market launch on 1 October 2021 — approach their five‑year term and are due to expire in October 2026; those seeking renewal will face additional scrutiny on areas such as gambling addiction prevention and advertising standards.

Key Points

From 1 January 2026, all remote gambling licence applicants must include an exit plan as part of their application.
The exit plan must detail how the operator would halt offerings in the Netherlands and fully withdraw if they do not extend beyond the initial five‑year licence period.
Applicants must also provide a document outlining how they will inform KSA of timely changes to policies and operations, plus an AML/CTF risk analysis.
Failure to meet the new requirements can result in application rejection, even for previously licensed operators.
Licences issued around the market opening (1 October 2021) expire October 2026 — renewals will be reassessed with extra focus on consumer protection and advertising rules.
Operators with regulatory failings in the first five years must explain remediation and how they will prevent recurrence; insufficient explanations can lead to refusal or additional conditions.

Context and relevance

This change signals tighter regulatory oversight as the Dutch regulated market matures. Requiring exit plans is part of a broader trend across jurisdictions to ensure orderly market exits, protect players, and limit consumer harm when operators leave a market. For operators and legal teams, this is a concrete administrative obligation they must factor into renewal planning ahead of the October 2026 deadline.

The amendment also underlines growing emphasis on AML/CTF compliance and operational transparency — areas regulators across Europe are increasingly prioritising. Firms operating in or entering the Netherlands should review governance, communications and contingency procedures now to avoid last‑minute rework.

Why should I read this?

Short version: if you operate in the Dutch iGaming market (or plan to), this directly hits your renewal checklist. KSA wants to see a clear exit playbook and proof you’ll tell them when things change — miss it and you risk having your application knocked back. Get your paperwork sorted early; it’s far easier than scrambling when deadlines loom.