KSA Fines EOD Code a Record €37.25m for Illegal Play on Instantcasino, Skyhills and 10 Other Sites

The Dutch regulator worked out a fine of €292.6 million from search data, then had to cut it to €37.25 million because the law caps penalties at 10% of worldwide turnover. The operator ignored a penalty order, left €840,000 in penalty payments unpaid and never answered the regulator.

• The Kansspelautoriteit (KSA) has fined EOD Code SRL €37,250,000 for offering unlicensed gambling to Dutch players through instantcasino.com, skyhills.com and 10 other sites, which it calls the highest fine it has imposed for illegal supply
• The previous record was the €24,846,000 fine on Novatech, announced in March
• The KSA estimated EOD Code's 2025 Dutch gross gaming revenue at €108.4 million from search volumes, set the fine at 270% of that, €292.6 million, then cut it to the legal ceiling of 10% of estimated worldwide revenue
• EOD Code is registered in San José, Costa Rica, according to the KSA, and left €840,000 in penalty payments unpaid, which the regulator moved to collect in December 2025
• The decision can still be challenged and the KSA has not said whether anything has been paid; its chairman wrote last week that such fines hardly work when it comes to collection

A Twelve-Site Operator That Never Answered the Regulator

The KSA announced on 22 October that it has fined EOD Code SRL €37,250,000 for offering games of chance in the Netherlands without a licence, in a decision dated 6 October and signed by chairman Michel Groothuizen. KSA staff were able to gamble on several of the company's sites "without any measures having been taken to prevent participation from the Netherlands", the regulator said in its announcement, in our translation.

Supervisors checked instantcasino.com six times between 19 November 2024 and 24 July 2026, opening an account with Dutch details, depositing €20 in Bitcoin and playing, according to the decision. "The Netherlands" was offered at sign-up and the +31 dialling code was filled in. In April 2026 the KSA found 11 more sites run by the same company: skyhills.com, slotmonster.com, betiro.com, betblast.com, fastslots.com, goldenpanda.com, sambaslots.com, winningz.com, incognitocasino.com, foxygold.com and luckypays.io. Five offered iDEAL and others listed Dutch banks as payment options. Dutch influencers promoted Skyhills, and four were served penalty orders in 2025.

EOD Code was already under a penalty order. Issued on 29 July 2025, it set €280,000 a week up to €840,000. Checks on 5, 12 and 19 September 2025 found Instantcasino still open to Dutch players, so the full €840,000 was forfeited. The company did not pay, and the KSA issued a collection decision on 11 December 2025, now final.

How €292.6 Million Became €37.25 Million

EOD Code did not respond when the KSA asked for its figures on 26 May 2026, or when it was invited to comment on the planned fine on 10 September. The regulator therefore used the search-volume method it published in February 2025, which estimates gross gaming revenue from how often a site is searched for, and put EOD Code's 2025 Dutch gross gaming revenue from the 12 sites at €108,374,000.

Under the KSA's 2026 fining policy for illegal remote gambling, the basic fine for estimated revenue of €800,000 or more is 100% of that revenue. The KSA added 170 percentage points for aggravating factors: 50 for no visible age verification, 20 for prohibited bets, 10 each for five others including crypto payments and inactivity fees, and 50 for unreasonable terms, among them a clause letting the company keep the balance of a player who asked for permanent self-exclusion.

The result was 270% of estimated Dutch revenue, €292.6 million. The Gambling Act caps a fine at 10% of turnover in the previous financial year, which the KSA reads as worldwide turnover, citing a 2026 Council of State ruling. It estimated EOD Code's worldwide 2025 revenue, by the same method, at €372,989,000, so the fine could not exceed €37,298,900. It was rounded down to €37.25 million.

Costa Rica on Paper, Curaçao Courts in the Terms

Despite a suffix more often seen on Romanian and Italian companies, EOD Code is registered in San José, Costa Rica, according to the KSA, citing Costa Rica's business register. Its sites said it is registered and regulated in Costa Rica, with the courts of Curaçao given exclusive jurisdiction. Instantcasino's terms once named Atlantis Interactive SRL, which Creditsafe says now trades as EOD Code. Neither decision cites any gambling licence. When Nederlandse Loterij took Skyhills to court in September, it named a Curaçao company, Skyhills N.V., as operator. The KSA, citing Creditsafe, attributes the site to EOD Code.

The fine is due within six weeks, the same window EOD Code has to object, and an objection does not suspend it. The KSA has not said whether any of the fine or the €840,000 has been paid.

The Cap Did the Fining, Not the Policy

For the second time this year, the cap, not the KSA's own fining scale, set the record. After the Novatech fine, Groothuizen told AD that without the cap the penalty would have been over €100 million, according to NL Times. Here the cap removed 87% of the calculated amount, leaving a fine equal to about a third of one year's estimated Dutch revenue. On the KSA's estimates, the Netherlands produced about 29% of EOD Code's worldwide revenue. While the ceiling stays tied to worldwide turnover, the more an operator depends on Dutch players, the less of its Dutch revenue a fine can reach.

A Fine Built on Search Data Invites a Fight Over Method

The whole number rests on an estimate the KSA made because EOD Code refused to share its figures, and an operator that wants it lowered has to open its books. The method has a weakness the KSA has itself named. Its spring 2026 monitoring report, which uses Google Ads search volumes to put channelisation by gross gaming revenue at an estimated 53%, says three illegal operators appear to have manipulated their search volumes, and they were removed from the data. If EOD Code objects, the method may be what is argued over.

Collection Is Where Records Stop Mattering

An operator that let €840,000 in penalty payments go to collection, and never replied to the regulator, is unlikely to pay €37.25 million. Groothuizen has said as much in general terms: fines on offshore operators that change names and sit outside Dutch reach are rarely paid. The more useful parts of this decision are probably the details that point to Dutch companies, such as iDEAL, Dutch bank options and Dutch influencers, which the KSA's payment and platform work can act on.

EOD Code now holds the record for an illegal-gambling fine in the Netherlands, worked out from an estimate and reduced by a cap. Whether any of it is collected will matter more than its size.