• Four Dutch MPs have submitted five formal parliamentary questions challenging the use of third-party licensing structures, with Evoke's 888 brand returning to the Netherlands via ComeOn Group's existing KSA licence cited as a specific example
• State Secretary for Justice and Security Claudia van Bruggen must respond within three weeks, with her answer expected to clarify whether operators with a history of unlicensed activity in the Netherlands can legitimately re-enter via a third party
• The MPs are also pushing on whether pre-KOA regulatory violations are properly weighted in licence application assessments and what measures the government is prepared to take to close the third-party licensing loophole
• The same two co-submitters, Mirjam Bikker and Sarah Dobbe, recently proposed legislation to remove the 10% global turnover cap on KSA fines, after the regulator was unable to exceed €24.8 million against Novatech despite indicating the penalty would otherwise have exceeded €100 million
• 888 returned to the Netherlands in 2025 after a three-year absence following the KOA's introduction in 2021, but its relaunch was not without issue, with the KSA issuing a warning in November over poor customer service accessibility

The Netherlands Is Asking Whether Its Licensing Framework Has a Loophole Problem

Dutch lawmakers are demanding answers about a practice that has quietly been reshaping which operators can access the Netherlands' regulated gambling market. A group of four MPs has submitted formal parliamentary questions targeting third-party licensing structures, raising concerns that companies with a problematic history in the Dutch market are finding ways back in through arrangements that may not be adequately scrutinised by the regulator.

The arrangement that has drawn the most attention is Evoke's strategic partnership with ComeOn Group, under which the 888 brand returned to the Netherlands in 2025. Rather than applying for a new KSA licence directly, 888 re-entered the market using a licence ComeOn Group already held for its Godwits brand. Evoke's own director of corporate development described the arrangement as a low-capital route to value creation, framing it as a commercially efficient re-entry strategy. From a regulatory perspective, however, the structure raises a different set of questions entirely.

The four MPs behind the questions are Mirjam Bikker, Sarah Dobbe, Diederik van Dijk and Tijs van den Brink. Bikker and Dobbe are listed as co-submitters and are not new to pushing hard on Dutch gambling regulation. Last month, the pair tabled a bill proposing the removal of the cap that limits KSA fines to 10% of an operator's global turnover, a move prompted by the regulator's record €24.8 million penalty against Novatech for illegal operations. The KSA itself acknowledged that without the cap, the fine would have exceeded €100 million, a figure that underscores how significantly the current ceiling constrains the regulator's deterrent power.

The parliamentary questions now put State Secretary for Justice and Security Claudia van Bruggen in a difficult position. She has three weeks to respond, though that period can be extended, and her answers are expected to address several interconnected issues. Chief among them is whether it is acceptable for operators known to have operated in the Netherlands without a licence to regain market access via a third party. She will also need to address the extent to which pre-KOA regulatory violations are factored into licence application assessments, the KSA's role in evaluating these arrangements, and what measures the government is willing to take to prevent third-party structures from functioning as a regulatory bypass.

The historical context matters here. The KOA legalised online gambling in the Netherlands in 2021, and many operators, including Evoke's 888 and William Hill brands, withdrew from the market ahead of the new framework going live. The departure of both platforms represented a significant revenue hit for Evoke. The three-year absence ended in 2025 with the ComeOn Group partnership, but the re-entry was not smooth. In November, the KSA issued 888 a formal warning criticising poor customer service accessibility, adding an early compliance concern to a relaunch that was already attracting scrutiny over the structure through which it was delivered.

ComeOn Group obtained its KSA licence in 2022 and joined Dutch trade association VNLOK in March 2026. The association has stated that licensing arrangements are assessed within the existing framework and that it is for the KSA to determine whether specific arrangements are permitted, while emphasising that its members are expected to comply fully with all rules and operate transparently.

Third-Party Licensing Structures Expose a Gap Between the Letter and Spirit of Regulation

The Dutch regulatory framework was designed to ensure that operators accessing the market meet defined standards of conduct, financial stability and player protection. Third-party licensing arrangements, where a brand with a chequered history effectively piggybacks on a cleaner operator's licence, create a structural tension with that intent. The question the MPs are asking is not whether the arrangement is technically permissible under existing rules, but whether those rules are adequate to capture the regulatory risk that such arrangements introduce. If an operator that previously served Dutch players illegally can return to the market without its historical conduct being a material obstacle, the licensing framework is doing less work than it appears to be on paper.

The State Secretary's Response Could Set a Defining Precedent

Claudia van Bruggen's answer to these parliamentary questions will carry consequences well beyond the specific case of 888 and ComeOn Group. If she confirms that pre-KOA violations weigh meaningfully on assessments of third-party arrangements, it sends a clear signal to any operator considering a similar route to market re-entry. If her response effectively endorses the current approach, it establishes that the licensing framework treats historical conduct as largely irrelevant once a third-party structure is in place. The KSA will be watching closely, since her answer will shape the regulatory authority it can exercise over these arrangements and determine whether the regulator needs additional legislative tools to scrutinise them adequately.

The Fine Cap Question and the Licensing Loophole Question Are Part of the Same Problem

Bikker and Dobbe's simultaneous push to remove the fine cap and their questioning of third-party licensing structures reflects a coherent regulatory philosophy: that the current Dutch framework has multiple points at which its deterrent and gatekeeping functions fall short of what they need to be. A regulator that cannot impose fines proportionate to the scale of an operator's global revenues, and that may be limited in how it can assess the history of operators entering via third parties, is a regulator whose tools are structurally mismatched to the market it is overseeing. Both issues need to be addressed together if the Netherlands is to have a framework that credibly disciplines licensed operators and controls who gets to participate in the market in the first place.