KSA Orders Endorphina to Keep Its Games Off Unlicensed Dutch Gambling Sites

The Dutch regulator found Endorphina slots on 28 unlicensed domains open to Dutch players, seven of them run by the operator it fined a record €37.25 million last month. It has not fined the studio, but rejected every argument it made against responsibility.

• The Kansspelautoriteit (KSA) has issued a binding instruction to Endorphina Limited of Malta and Endorphina Ltd. of Cyprus for failing to stop their games appearing on unlicensed sites in the Netherlands
• The KSA says that promotes unlicensed gambling, banned by Article 1(1)(b) of the Betting and Gaming Act; there is no fine, and Endorphina had two weeks to act and report back
• Supervisors found Endorphina games on unlicensed sites between January and September 2026, including seven run by EOD Code, fined €37.25 million
• Endorphina argued that its Maltese and Cypriot companies are separate and that a visible logo does not prove supply; the KSA rejected both
• The decision is dated 19 October and was published on 2 November, the day Endorphina announced a PointsBet Canada deal

The KSA Turns Its Enforcement on a Games Studio

The KSA published the binding instruction on 2 November. Signed on 19 October under Article 34n of the Betting and Gaming Act (Wet op de kansspelen), it is neither a fine nor a penalty order. It requires Endorphina, within two weeks of the decision date, to take adequate measures against promoting unlicensed gambling in the Netherlands and to inform the regulator, for example through technical and contractual measures with the operators and distributors that take its games.

According to the decision, supervisors on Dutch IP addresses played Endorphina titles, among them Hell Hot 100 and Crown Coins, in January and February 2026, in June, and on 29 and 30 September. The three rounds name 28 domains, including instantcasino.com, betiro.com, betblast.com, fastslots.com, goldenpanda.com, sambaslots.com and winningz.com, all EOD Code sites. The operators of qbet.com and luckygem.com were already under penalty orders, yet Endorphina games were still playable there. The KSA saw no measures blocking Dutch players, and Endorphina's name and logo appeared on the sites, in game URLs and under each game.

Endorphina Disputed Responsibility for Six Months

The KSA first contacted Endorphina on 2 April 2026, the decision records. Endorphina said on 7 May that contractual confidentiality stopped it sharing everything, and on 14 May that there was no evidence it knowingly supplied illegal operators. In written views on the proposed instruction, it argued that its Maltese and Cypriot companies have separate licences, contracts and remote game servers, that the KSA had not shown which supplied the recorded sessions, and that it also distributes through licensed B2B intermediaries. It said that in July it restricted access on every site the KSA had named, without admitting a breach.

The KSA rejected each point. The two companies filed identical views through the same contact person and coordinated their measures, it says, and a redacted chart shows one individual as a director of the Cypriot company and sole shareholder of the Maltese one. Endorphina never sent the results of its own investigation, according to the regulator, and a registered trademark holder can be expected to act against misuse. Intent and which entity supplied the games are irrelevant to a binding instruction, the KSA says, and September checks found the games still available.

Endorphina can object within six weeks, which would not suspend the instruction, and has published no response.

The KSA Is Reaching Past the Operator to the Content

Dutch enforcement has mostly targeted operators and payment and internet intermediaries, and the KSA is working with Google on an EU white list. In 2019 it issued penalty orders to Gaming Innovation Group and Innovation Labs for advertising unlicensed operators. Its publication decision says this case is meant to warn other game suppliers too. A binding instruction is the softer tool, used, the decision says, where an intermediary may be providing crucial services without knowing it. After six months of correspondence and a published decision, that rationale is harder to apply to Endorphina.

Attribution Was the Defence, and the KSA Treated It as Beside the Point

Endorphina's strongest argument was that a brand on a site does not prove who served the game. The KSA did not trace the supply chain; it said it did not need to, because Endorphina had the means and the information to act. It adds, without detail, that keeping games off unlicensed sites requires no extensive or complicated technical work. The decision does not say what follows if Endorphina fails to comply, and that is the real test of an instruction without a fine.

The Same Titles Serve Both Markets

The KSA says Endorphina's games are also offered by licensed Dutch operators, and that seeing them on an unlicensed site can make that site look trustworthy. That is channelisation in miniature: the KSA chairman has said half of every euro goes illegal, and familiar content helps the illegal market look legitimate. On publication day, Endorphina announced a PointsBet Canada partnership in Ontario that it calls its first major North American step, naming Hell Hot 100 and Crown Coins among its popular titles there.

The KSA has put a games studio on notice without fining it. Whether that is enough will be shown by the next round of checks, not by the paperwork.