The Dutch gambling regulator Kansspelautoriteit (KSA) has fined Costa Rica-registered operator EOD Code SRL a record €37 million for offering unlicensed online gambling to players in the Netherlands. The penalty, which covers twelve websites including Instantcasino and Skyhills, is the largest the KSA has ever imposed for illegal gambling provision.
The size of the fine, and the method used to calculate it, signals that the regulator is prepared to pursue offshore networks more aggressively, even though it has acknowledged that most such penalties are never collected.
What happened to EOD Code
Kansspelautoriteit investigators tested Instantcasino repeatedly between November 2024 and July 2026, registering with Dutch address details, using the Netherlands’ +31 telephone code, depositing Bitcoin and gambling
.
No technical controls prevented participation from a Dutch IP address.
The investigation that began with Instantcasino subsequently uncovered eleven further sites linked to the same operator, among them Skyhills, Slotmonster, Betiro and Betblast.
The sites accepted cryptocurrency and anonymous payment methods, which the KSA said encourages money laundering
. The regulator had already tried to stop EOD Code once before.
It had ordered EOD Code in July 2025 to stop offering unlicensed gambling in the Netherlands, but follow-up inspections in September found Dutch players could still access Instantcasino, triggering the maximum €840,000 in periodic penalty payments, which the company did not pay.
Because the operator ignored requests for financial information, the KSA built its own estimate of EOD Code’s earnings.
The regulator estimated EOD Code’s 2025 Dutch gross gaming revenue at €108.4 million from search volumes, set the fine at 270% of that figure, then cut it to the legal ceiling of 10% of estimated worldwide revenue.
Dutch law limited the sanction to 10% of the company’s estimated worldwide turnover, which the regulator placed at €372.989 million for 2025, reducing the maximum to €37.2989 million before the Ksa rounded the final penalty down to €37.25 million. EOD Code can object within six weeks, but filing an objection does not suspend the decision.
Why it matters
The EOD Code case shows the KSA is willing to use revenue-based fines even when an operator refuses to cooperate, reconstructing turnover estimates from external data rather than letting non-disclosure limit enforcement. For licensed Dutch operators, that raises the bar on compliance expectations, since the regulator is demonstrating it can match penalties to the actual scale of an illegal operation rather than relying on fixed administrative fines that offshore brands can simply absorb as a cost of doing business.
For affiliates and performance marketers, the case is a reminder that promoting unlicensed brands carries growing reputational and legal exposure as regulators sharpen their investigative methods. A linked concern raised by the KSA this month is that
generative AI chat and search assistants frequently direct users towards online gambling sites lacking official Dutch licences
, meaning organic and AI-driven discovery channels are themselves becoming a regulatory target. Affiliates operating in regulated markets such as the Netherlands will need to keep licensing checks current as part of their due diligence, since search visibility for an unlicensed brand can now attract direct scrutiny.
The bigger picture
The EOD Code penalty breaks a record set only seven months earlier.
The fine for the operator of Instant Casino tops the €24.8m sanction handed out by Kansspelautoriteit to Novatech in March
, the Curaçao-based operator behind Qbet and 55Bet. The escalating scale of these penalties points to a regulator testing how far turnover-based calculations can be pushed against operators who refuse to engage.
Yet the KSA itself has conceded the limits of fines as a deterrent.
The regulator has admitted that fines against unlicensed operators are almost impossible to collect, meaning they are never paid and have no material impact on the operator under the spotlight, and confirmed in January that it was taking enforcement action to collect a previous fine of €840,000 after the Costa Rican firm failed to pay and continued targeting Dutch players. According to the KSA, 97.5% of the €56.4m in penalties issued to unlicensed operators since market legalisation in 2021 have gone unpaid.
That collection problem is likely to keep pushing the regulator towards working with payment providers, hosting companies and large technology platforms alongside headline fines against companies such as EOD Code.
The case sits alongside a broader pattern of European regulators tightening enforcement around licensing compliance, a theme covered recently in our report on L&L Europe’s £900k settlement with the UK Gambling Commission. For more coverage of regulatory and licensing developments across the sector, visit our industry news section.
Sources
- CasinoBeats – Dutch regulator fines EOD Code record €37m over twelve illegal casinos
- iGaming Business – KSA imposes record €37 million fine on unlicensed operator managing over 10 sites
- NL Times – Dutch Gambling Authority issues record 37 million euro fine to illegal casino operator
- iGaming Times – Instantcasino Operator EOD Code Gets Record KSA Fine of €37.25m
- iGaming Expert – Dutch Market regulator must move beyond fines to tackle black market
- iGaming Express – EOD Code Receives Record Dutch Fine
- InterGame Online – KSA hands out record fine to Instant Casino operator EOD Code
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