Ksa fines Instantcasino operator a record EUR 37.25m

The Kansspelautoriteit (Ksa), the Dutch gambling regulator, has fined EOD Code SRL EUR 37,250,000 for offering online gambling in the Netherlands without a licence. Ksa announced the fine on 22 October. It says this is the highest fine it has imposed for illegal gambling so far. The decision is dated 6 October 2026 and was sent to the company on 7 October.

EOD Code can still lodge an objection (in Dutch, bezwaar) with Ksa. The fine is therefore not final, and there is no indication that it has been paid.

The twelve sites Ksa named

Ksa's investigation started with Instantcasino. Further checks found eleven more sites that, according to Ksa and company data it obtained from Creditsafe, are run by the same company. The full list as Ksa gives it:

• Instantcasino
• Skyhills
• Slotmonster
• Betiro
• Betblast
• Fastslots
• Golden Panda
• Samba Slots
• Winningz
• Incognito Casino
• Foxy Gold
• Luckypays

None of these sites holds a Dutch licence. Ksa staff were able to open accounts with Dutch details, deposit and play on them, and the regulator found no technical measures to keep players in the Netherlands out. According to the decision, the sign-up forms pre-filled "The Netherlands" as the country, and the payment pages, at least partly in Dutch, listed iDEAL or Dutch banks. On Instantcasino, an inspector deposited EUR 20 in Bitcoin from the Netherlands.

Ksa also lists a series of aggravating factors. There was no visible age check before sign-up was completed, so Ksa could not rule out that minors had access. Players could deposit in cryptocurrency and other anonymous payment methods, which Ksa says can facilitate money laundering. The decision also points to autoplay or turbo play, no or pre-filled play limits, and an inactivity fee of EUR 5 a month from the thirteenth month of an unused account.

Ksa singled out several terms it calls unreasonable for players. Withdrawals were capped at EUR 4,000 a day, EUR 10,000 a week and EUR 20,000 a month. Money that had not been staked at least once could be charged a fee on withdrawal. Players' funds could fall into the company's estate in a bankruptcy. And a player who asked for permanent self-exclusion could, under the terms, lose their remaining balance.

A repeat case

This is not Ksa's first action against EOD Code. In July 2025 it imposed an order subject to penalty payments (last onder dwangsom) requiring the company to stop. Checks in September 2025 found Instantcasino still open to Dutch players. In December 2025 Ksa decided to collect EUR 840,000 in penalty payments the company had forfeited. Ksa said at the time that this amount had not been paid, and AD.nl reported on 22 October that it still has not. Ksa had already acted separately against Dutch influencers who promoted Skyhills.

EOD Code did not respond when Ksa asked for its view on the planned fine in September 2026, nor to a data request in May 2026.

Why EUR 292.6 million became EUR 37.25 million

The way Ksa reached the figure explains why the fine is large, but much smaller than the regulator's own starting point.

Because EOD Code supplied no figures, Ksa estimated its revenue using its search-volume method, which works from how often people search for the sites. On that basis it put the company's gross gaming revenue from Dutch players in 2025 at EUR 108,374,000. Gross gaming revenue is the amount staked minus the amount paid out in winnings.

Under Ksa's fining rules, the base fine for revenue of that size is 100% of that amount. Ksa then added 170 percentage points for the aggravating factors listed above, arriving at 270%. That gave EUR 292.6 million.

The Dutch Gambling Act (Wet op de kansspelen), however, caps a fine at 10% of the company's turnover in the financial year before the decision, and Ksa reads that as worldwide turnover. It estimated EOD Code's worldwide gross gaming revenue for 2025 at EUR 372,989,000, again with the search-volume method. Ten percent of that is EUR 37,298,900. Ksa then reduced the fine to that ceiling and rounded it down to a multiple of EUR 50,000, which gives EUR 37.25 million.

In plain terms: the cap is set by the size of the whole business, not by what it earned in the Netherlands. By our calculation from Ksa's estimates, more than a quarter of EOD Code's worldwide revenue came from Dutch players, and the cap cuts the fine by roughly seven-eighths.

Will it be collected?

That is the open question. AD.nl, which reports that the company operates from Costa Rica, notes the earlier unpaid penalty payments. According to the decision, the Instantcasino website itself stated that EOD Code was registered and regulated in Costa Rica, with the courts of Curaçao named for disputes. AD also cites Ksa telling the website CasinoZorgplicht.nl this summer that at least 97.5% of the EUR 56.4 million in fines imposed last year was not paid. Ksa says it also tackles illegal gambling by working with payment service providers, hosting companies, banks and large tech firms. We covered one example of this, Ksa's plan for a legal-operator list with Google.

What it means for players in the Netherlands

If you play from the Netherlands, none of the twelve sites above is licensed by Ksa. That means none of the Dutch protections applies, such as age and identity checks, play limits and access to the national self-exclusion register, Cruks. In its decision to publish the fine, Ksa also points out that taking part in an unlicensed game, knowing it has no licence, is itself an offence under the Dutch Gambling Act. Ksa's register of licensed operators is the place to check a site. We wrote recently about the first eight Dutch online licence renewals and about Ksa's rule on wagering deposits before withdrawal.

This fine is separate from the civil action by Nederlandse Loterij against Skyhills in September, which we covered in Dutch players shut out of Skyhills.