This week, the Dutch Gambling Authority, also referred to as Kansspelautoriteit or KSA, published the results of a study reviewing the current risk analysis system for licensed online casino games. The Netherlands’ gambling regulator concluded that the system does not work effectively.
KSA’s research was carried out between late 2024 and early 2025 and examined how licensed online casinos used the ‘duty of care’ protocols. These measures were introduced when the country launched its legal iGaming in October 2021.
They are designed to prevent and reduce gambling addiction by enabling operators to evaluate the risks of their offerings and implement protective measures when necessary.
Duty of Care and Risk Analysis Requirements
Licensed entities, including iGaming operators, providers, casino branches, and slot machine locations, must conduct their risk assessments either internally or through external consultants. The objective is to identify the risks associated with games and help operators develop and implement protections.
Some protective measures include player-defined betting limits, pop-up reminders, and behavioural feedback tools, explained the Gambling Authority. As part of their obligations, casino platforms must also record these measures and include them in their addiction prevention policies.
Study Design and Scope
In its statement, KSA explained that the study primarily focused on risk analyses carried out by operators since the launch of the iGaming market. It examined the methods used, the third-party organisations conducting the analyses, and the departments or officers responsible for the operator’s policies.
The study also reviewed academic literature on risk analysis methods. It identified two approaches, which operators utilised in their assessments. They were Asterig and Gamgard. Both methods, however, are known to have limitations.
Asterig, developed in 2010 and updated in 2013, is publicly available but criticised for its reliability, validity, and applicability. Meanwhile, Gamgard is a proprietary method used by a dedicated team, but its transparency has been questioned.
Methods Utilised by Licensed Entities
KSA’s study found that licensed operators relied on five different methods for analysing game risks. Asterig and Gamgard were among the most commonly used.
Additionally, the risk analyses were mainly performed at the game category level instead of on individual casino products. This approach is used due to the immense number of games in operators’ libraries. However, it may underestimate the risks that can be in specific games within a category or vertical.
The study further revealed that analyses were conducted by staff members, third-party consultants, or a combination of both. In some cases, external parties prepared analyses for each category, which internal staff then applied to daily operations. It was determined that 21 licensees used help from a third-party, while seven conducted the analyses themselves.
Inconsistencies in Risk Scores
However, KSA’s research found several issues with risk scoring. For instance, slots and video poker were often marked as ‘high-risk,’ with jackpot slots labelled as even riskier. Then, pre-match sports betting was described as lower risk than live betting.
In the meantime, table games, such as blackjack and roulette, had the largest variations. They were marked from low to very high risk, depending on the used risk assessment method and the licensee. Even when a consultant used the same method across multiple operators, results were rarely similar.
These discrepancies can be explained by the differences in analyst interpretation, operator data, and whether the mitigation protocols were considered. Protocols like betting limits and pop-up messages, when taken into account in a risk score, could drastically affect the determined risk level.
Application in Addiction Prevention Policies
Licensees are required to incorporate the results of their risk analyses into their addiction prevention policies. However, the study unveiled that many policies essentially restated statutory requirements with little additional explanation. This makes it difficult to assess how analyses are applied in practice or how effective measures are in safeguarding the consumers.
Still, several operators did fine with their practices. These gaming brands surpassed regulatory minimums, focusing on rapid interventions for high-risk games and restricting marketing for these products. Thanks to their proactive approaches were found to have best practices within the current framework.
Main Findings and Conclusions
The KSA concluded that the current risk analysis system is ineffective. Although conducting these analyses requires considerable effort and expense for operators, they offer limited additional protection for players. Some of the key findings include:
- Methods under discussion: Five methods are used by operators, with Asterig and Gamgard being the most common ones. But both are known for their limitations, and it can be said to be slightly outdated.
- Inconsistent outcomes: Risk analyses for the same games can vary between operators and the methods used.
- Outcomes are not comparable: Some operators include mitigation measures in their risk scores, while others do not, making it difficult to create valid comparisons.
- Concerns over expertise: Internal analysts may lack independence, and the quality of external analysts varies.
- Categorised analysis: Conducting analyses at the category level may underestimate risks for specific games.
What’s Next?
The KSA will be working with the Ministry of Justice and Security to find ways to improve the country’s risk analysis system. The objective would be to establish a more standardised and efficient framework. Thus, ensuring that all licensed operators can assess and mitigate risks consistently while enhancing player protection.
