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KVA expressed concern over the potential manipulation of Google’s autocomplete function by unauthorised operators and websites primarily set up to redirect Dutch consumers to illegal gambling offers.
While acknowledging Google’s cooperation in removing paid advertisements promoting illegal casinos, the KVA emphasised the need for the company to take more comprehensive measures addressing organic search results.
Dutch MPs have raised similar concerns before. In December 2025, CDA MP Straatman asked the state secretary whether websites advertising as “Beste casino’s zonder Cruks” should be taken offline immediately.
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Regarding account takeovers, the guide emphasised technical mitigations such as two-factor authentication for withdrawals and changes to banking details.
For poker collusion and bot use, recommended contractual provisions allow operators to redistribute illegitimate winnings to affected players. The guide noted that courts have validated such actions when supported by robust data.
The ANJ has called for operators to provide proof rather than act on suspicion alone. The guide outlined the types of evidence and “converging indicators” (faisceaux d’indices) that French courts have accepted in previous litigations, including IP addresses, device logs and connection timings.
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Sponsorship activities involving children and adolescents, schools, and youth sports categories are also prohibited. Betting companies will also be banned from associating their brand with campaigns or projects related to mental health, suicide prevention, financial education, treatment of gambling disorders, social assistance, prevention of over-indebtedness or protection of vulnerable families.
Operators may not use data from individuals who have self-excluded, are undergoing treatment, or have requested to block marketing in order to attempt to reactivate them. Repeated or intrusive messages and offers directed at users who have reduced their gaming frequency, registered significant losses, triggered limits or shown signs of risky behaviour are also prohibited.
The text also bans exploiting situations of economic crisis, unemployment, debt, emotional distress, grief, anxiety, depression, loneliness, or other conditions of vulnerability to attract, retain or reactivate gamblers.
