Netherlands iGaming Exit Plan: What Licensed Operators Must Know
March 19, 2026
Every operator active in the Netherlands iGaming market — or applying to enter it — now faces a requirement that goes beyond the usual compliance checklist: a formal exit plan. Since January 1, 2026, the Kansspelautoriteit (KSA) has made this a mandatory part of every license application, license change and renewal. It is not a formality. Get it wrong, or leave it vague, and the KSA can refuse your application outright.
This article explains the three scenarios that trigger an exit, what an orderly withdrawal actually demands of you, and how player protection sits at the center of it all.
Why Would a Licensed Operator Exit the Dutch Market?
Not every exit looks the same. The KSA distinguishes between three fundamentally different situations, and your exit plan must address all of them.
Voluntary Exit
This is the straightforward scenario: you decide not to renew your license at the end of the license term, or you make a commercial decision to leave the market before then. Several operators made exactly this choice after various marketing restrictions and the Dutch gambling tax rose to 34.2% in 2025 — and with the rate climbing further to 37.8% in 2026, more are weighing their options. A voluntary exit is planned and within your control. That makes it the most straightforward to document, but the obligations toward your players remain fully in force until the last player account is closed.
Mandatory Exit
This scenario is imposed on you. The KSA can suspend or revoke your license for non-compliance — whether that is repeated advertising violations, failure to meet AML obligations (in Dutch WWFT), or failure to comply with enforceable court rulings. The KSA has been explicit: operators with unresolved court rulings at the time of application are considered unreliable, which constitutes grounds for refusal. A mandatory exit leaves you with less time and less control, which is precisely why your plan needs to anticipate it.
Forced Exit
This is the scenario operators least want to think about: insolvency, a technical failure that makes it impossible to continue offering services, or another circumstance beyond your control. A forced exit is the hardest to execute in an orderly way, but it is also the scenario where player protection is most at risk. Your plan must account for it.
What Does an Orderly Exit Actually Require?
The KSA frames the exit plan as a best efforts obligation. This is a meaningful legal distinction. It means you are not expected to produce a perfect outcome in every conceivable situation — but you are required to demonstrate that you have planned seriously, in advance, for a range of scenarios. A vague, single-scenario document will not meet the standard.
Legal and Financial Obligations
During any withdrawal, your regulatory obligations do not pause. You must continue to meet WWFT and AML reporting requirements until your license is formally extinguished. Outstanding contractual commitments with software providers, payment processors, and other third parties all need a structured wind-down plan. Financial continuity — your ability to meet obligations as they fall due — is something the KSA will scrutinize closely.
Technical and Operational Steps
Your plan must describe the specific steps for phasing out your gambling offering: disabling player registration, closing game access, disconnecting from the KSA's control database (CDB), and notifying platform and software partners. Timelines matter here. The KSA expects you to demonstrate that withdrawal can be executed in a structured, controlled way — not as an emergency shutdown.
Communication to the Regulator
Under the updated Remote Gambling Policy Rules 2026, operators must also submit a separate document explaining how they will keep the KSA informed of material changes to their policies and operations throughout the license period. This obligation sits alongside — and feeds directly into — the exit plan requirement.
Player Protection: The Non-Negotiable at the Center of It All
If there is one area where the KSA has drawn a clear line, it is player protection during an exit. The obligation to process outstanding withdrawals, settle open bets, and communicate proactively with players does not disappear when a license ends. It applies throughout the withdrawal period and takes priority over other creditor claims.
What Operators Owe Their Players
At minimum, your exit plan must set out how you will process all pending player withdrawals promptly, close player accounts in compliance with the Wet op de kansspelen (Dutch Gambling Act), communicate clearly and – where possible - in advance about the timeline of the exit, and maintain player access to their account history and any relevant documentation.
How the Player Protection Foundation Connects
The KSA's player funds separation requirement — which uses a dedicated Stichting (foundation) structure to ring-fence player balances from the operator's own assets — is directly linked to exit planning. The Stichting acts as an independent safety net: if the operator can no longer fulfil its financial obligations, the foundation holds the player funds separately, ensuring they remain accessible. For operators already complying with the separation of player funds requirement, this structure also provides the clearest evidence — to the KSA and to players alike — that an orderly exit is genuinely possible.
This is where our Foundation solution comes in. Designed specifically for Dutch-licensed operators, it establishes the Stichting structure that ring-fences player funds independently of your operating entity — satisfying the KSA's separation requirement and giving you a ready-made financial safety net for any exit scenario. If you have not yet put this in place, doing so now — as part of your exit plan preparation — is the most efficient approach.
Building a Practical Exit Plan: What the KSA Expects
The best efforts standard means the KSA is looking for substance, not box-ticking. Here is what a credible plan includes.
Scenario Coverage
Your plan must address all three exit types — voluntary, mandatory, and forced — with tailored timelines and procedures for each. A single generic withdrawal procedure will not suffice. Each scenario has different triggers, different time constraints, and different stakeholders to manage.
Clear Ownership and Timelines
The KSA expects to see who is responsible for each step, not just what needs to happen. Assign specific roles within your organization for regulatory notification, player communication, fund management, and technical shutdown. Attach realistic timelines to each phase, and ensure those timelines are achievable under the most constrained scenario — a forced exit — not just under favorable conditions.
Player Communication Plan
Specify the channels, timing, and content of player communications for each exit scenario. Players must receive advance notice wherever possible.
Keeping the Plan Current
A plan written at license application and never revisited is a liability, not an asset. As your business evolves — new payment providers, new verticals, structural changes — your exit plan must evolve with it. Build in a review cycle and document it.
We have developed an exit plan framework that meets the above requirements and can be tailored to your specific situation. If you would rather not start from a blank page, our Amsterdam team is available to help.
Frequently Asked Questions
Both. The KSA requires an exit plan from every applicant — whether you are applying for the first time, making changes to your existing license or renewing after the initial five-year term. There is no exemption.
The KSA can deny your application or impose additional conditions and restrictions on your license. This applies even if you have held a Dutch license previously. The regulator has made clear that the exit plan is a fundamental element of any application.
Yes. The obligations are the same across all scenarios, but the timelines and practical steps differ significantly. A voluntary exit gives you time to plan carefully. A mandatory or forced exit does not. Your plan must be realistic and operable under each set of conditions — not just the most comfortable one.
The Bottom Line
The KSA's exit plan requirement reflects a straightforward regulatory logic: if you are allowed to operate in the Dutch market, you must also be able to leave it in an orderly way. Operators who approach this as a serious operational document — rather than a compliance formality — will be better positioned for both renewal and the unexpected.
We have been active in the Dutch iGaming market since it opened in October 2021, and we have supported operators through every stage of the licensing process. If you need help structuring your exit plan, aligning it with your player funds separation obligations, or preparing your renewal application, our team in Amsterdam is ready to help. Get in touch.
Written by Kees-Jan Avis
