€290 Million by the Formula, €37.25 Million after the Cap: Netherlands Issues Its Largest-Ever Fine for Unlicensed Gambling to EOD Code

File photo: The Hague skyline, 21 July 2013. Geographic context only; not EOD Code premises or the penalty announcement. Photo: Roman Boed / Wikimedia Commons, CC BY 2.0. Display cropped to fit. Image source.

Page 15 of the Dutch Gambling Authority’s fine decision: the table of aggravating circumstances and the calculation reducing €292.6 million to €37.25 million. Source: Kansspelautoriteit

The Dutch Gambling Authority (Kansspelautoriteit, KSA) announced on October 22 that it had fined EOD Code SRL €37.25 million for offering gambling services to Dutch players without a Dutch licence through a group of websites including Instantcasino and Skyhills. KSA said this was its largest fine to date for illegal gambling. The fine decision was dated October 6 and sent on October 7.

12 Websites, One Company

The decision shows that KSA initially investigated Instantcasino. During five inspections between November 19, 2024, and July 8, 2025, investigators were able to open accounts, deposit money and place bets using Dutch IP addresses and Dutch addresses. The website had taken no technical measures to block Dutch players. On July 24, 2026, KSA checked again through the site’s alternative domain, Instantcasino17, with the same result.

Further investigation found that EOD Code also operated 11 other websites: Skyhills, Slotmonster, Betiro, Betblast, Fastslots, Goldenpanda, Sambaslots, Winningz, Incognitocasino, Foxygold and Luckypays. In inspections between November 2025 and June 2026, KSA confirmed that these websites were also accessible from the Netherlands: the country field at registration was automatically filled with “The Netherlands”; +31 was available as a telephone country code; the payment process was wholly or partly in Dutch; and payment options included iDEAL or Dutch banks such as Rabobank, ING, ABN AMRO and ASN Bank. KSA found that company information from Creditsafe also identified EOD Code as the operator of these websites.

The websites claimed to be registered and regulated in Costa Rica. Their user terms stated that Costa Rican law applied and that the courts of Curaçao had exclusive jurisdiction over disputes.

Influencer Promotion and Cryptocurrency Deposits

The decision noted that several Dutch influencers posted promotional links leading directly to Skyhills on Instagram, YouTube and Discord. Videos featuring Dutch-language text and the Skyhills logo also appeared on TikTok. KSA had previously issued orders subject to periodic penalty payments to LeftlanePapi, Turcos, StiefunSpeelt and Buurtwachtt over these promotions. A Dutch-language gambling affiliate website also advertised Instantcasino.

Investigators deposited €20 from the Netherlands using bitcoin, after which the account balance was displayed in euros. KSA considers the acceptance of cryptocurrency and anonymous payments to facilitate money laundering and tax evasion.

How the Fine Was Calculated

EOD Code did not respond to KSA’s May 26 request for data and did not submit comments on the proposed sanction. KSA therefore estimated its revenue using the “search-volume method” published in February this year: first identifying the keywords players used to find these websites and their search volumes, then applying a formula to estimate gross gaming revenue (GGR).

• The 12 websites’ GGR from the Netherlands in 2025 was estimated at €108.374 million.
• Under the 2026 policy rules on fines for illegal remote gambling, the base fine is 100% of GGR where GGR is €800,000 or more.
• Eight aggravating circumstances added a total of 170 percentage points: no visible age verification (50), offering prohibited types of bets (20), charging inactivity fees (10), automatic or accelerated spins (10), no betting limits or pre-filled limits (10), deposit amounts (10), deposit methods (10), and other unfair provisions in the terms (50).
• The total came to 270% of GGR, or €292.6 million.

However, Article 35a of the Gambling Act provides that the fine may not exceed 10% of worldwide turnover in the previous financial year. Using the same method, KSA estimated EOD Code’s worldwide GGR for 2025 at €372.989 million, producing a fine cap of €37.2989 million. Rounded down to a multiple of €50,000, the fine was set at €37.25 million. On this estimate, the Dutch market accounted for about 29% of EOD Code’s worldwide revenue.

The “Traps” in the Terms

KSA listed several provisions in the user terms that it regarded as particularly aggravating circumstances: €5 deducted from the balance each month after 12 consecutive months of account inactivity; a fee for withdrawing funds that had not been wagered at least once; daily, weekly and monthly withdrawal limits of €4,000, €10,000 and €20,000 respectively; the possibility that player funds could become part of the insolvency estate if the operator went bankrupt; a disclaimer of liability for deviations in game fairness caused by technical faults; and the operator’s right to confiscate the account balance when a player requested permanent self-exclusion.

Periodic Penalty Payments Had Already Been Imposed

This was not KSA’s first action against EOD Code. On April 10, 2025, KSA issued notice of its intention to impose periodic penalty payments, followed by a formal order on July 29: €280,000 for each week, or part of a week, of non-compliance, up to a maximum of €840,000. Because the websites continued to be accessible from the Netherlands, KSA decided on December 11, 2025, to collect the full €840,000 in penalty payments. No objection was lodged against that decision, which has become final.

An objection to the new fine decision may still be lodged within six weeks of its dispatch, but an objection does not suspend enforcement of the decision. The fine must be paid in full within six weeks, with statutory interest accruing on overdue payment. KSA’s announcement did not say whether EOD Code would pay or lodge an objection.

KSA said in its announcement that, in addition to administrative fines, its efforts to combat illegal gambling also relied on cooperation with payment service providers, hosting providers, banks and major technology companies.

Sources

• KSA press release (October 22, 2026): https://kansspelautoriteit.nl/nieuwe-recordboete-illegaal-kansspelaanbod-opgelegd-37-miljoen-voor-eod-code
• KSA’s EOD Code SRL enforcement-decision overview: https://kansspelautoriteit.nl/eod-code-srl
• Fine decision (October 6, 2026, public version): https://kansspelautoriteit.nl/sites/default/files/2026-10/2026-10-06_20970_Boetebesluit%20instantcasino.pdf
• Decision to collect periodic penalty payments (December 11, 2025): https://kansspelautoriteit.nl/sites/default/files/2026-01/2025-12-11_20970_invorderingsbesluit%20EOD%20Code%20SRL._sanctiebesluit.pdf
• Order subject to periodic penalty payments (July 29, 2025): https://kansspelautoriteit.nl/sites/default/files/eod_code_srl_18933_lod_20250729.pdf