KSA overhauls deposit means-test rules for Dutch operators

The Dutch gambling regulator Kansspelautoriteit (KSA) has revised its guidance on the financial means test operators must run before raising player deposit limits, reversing one of its own previous recommendations in the process. The updated good-and-bad-practices document, announced on 2 July 2026, removes savings and other assets from affordability calculations entirely and nearly doubles the list of practices the regulator explicitly prohibits.

The revision follows a second round of compliance checks at 20 licence holders, in which the KSA assessed real means-test cases. The regulator said many operators had improved their approach since the first version of the document was published in February 2025, but that shortcomings and breaches persisted. Across the sample, the KSA held ten improvement conversations, issued three formal warnings and imposed one binding instruction.

Savings no longer count as income

The most significant change is a correction of the KSA’s own earlier position. The February 2025 guidance had listed, as a good practice, allowing operators to count 5% of a player’s liquid assets, spread over 12 months, towards the monthly net deposit limit. That practice has now been removed entirely.

The updated document states that structural income is the sole basis for the calculation. Liquid assets such as savings, and non-liquid assets such as home equity or business equity, must play no part in the assessment at all. The KSA said its earlier wording on this point had caused confusion among operators in practice.

The means test itself has been mandatory since 1 October 2024 under the Beleidsregel verantwoord spelen 2024. Licensed operators must assess a player’s financial capacity before allowing monthly net deposits above €300 for players aged 18 to 23 and €700 for players aged 24 and over. Where affordability cannot be established, further deposits must be blocked for the remainder of the calendar month.

Good practices expand to seven

The updated document lists seven recommended practices, up from six. Carried over largely unchanged are three existing entries: never allowing players under 24 to raise their net deposit limit above €300 regardless of income, applying a lower proportion than the standard 30% of net income when calculating safe spending for low earners, and keeping thorough records of how each limit was calculated.

Two entries are new. Operators should take a player’s risk profile into account even where income would otherwise support a higher limit, and should set the term of a deposit limit with reference to a player’s retirement age or a temporary employment contract, since income in those situations can change quickly.

The regulator also now recommends using multiple recent payslips, or an average of cumulative pay, rather than a single figure. A previous good practice allowing separate daily and weekly limits alongside the monthly one has been dropped from the new version.

Prohibited practices nearly double to 13

The list of practices the KSA warns against has grown from seven to 13. Recurring themes include accepting a player’s own income declaration instead of verifiable documents such as payslips or tax returns, and using a player’s highest payslip rather than a recent or average one.

New entries include using public benchmark figures rather than a player’s actual circumstances to estimate safe spending, treating the balance of a payment account as income, and having too little insight into calculations carried out by a third party where means testing has been outsourced. The KSA stressed that operators retain full legal responsibility for outsourced testing.

The regulator also lists receipts that must never be counted as a player’s income: a partner’s or child’s income, loans, and earmarked benefits such as child benefit or housing allowance. For business owners, the test should be based on the most recent definitive tax returns or annual figures, not gross income such as dividend payouts or company balance sheet assets.

Supervision continues under the new baseline

The tightening fits a wider pattern of Dutch enforcement around duty-of-care obligations, an area where the regulator has been active since Carol Verheij joined the KSA board as vice chair earlier this year. It also mirrors moves elsewhere in Europe, where the UK Gambling Commission has issued technical guidance on dynamic stake limits and set hard compliance deadlines for bonus and wagering rules.

The KSA said it will keep supervising how operators apply the means test and will carry out further sample checks measured against the newly updated guidance. Operators whose calculations still rely on assets, self-declarations or third-party tools they cannot fully explain now have a clear baseline against which the next round of checks will be judged.

Source: Kansspelautoriteit