Dutch regulator fines Instantcasino operator a record €37.25 million

The Dutch gambling regulator, the Kansspelautoriteit (Ksa), has fined EOD Code SRL €37,250,000 for offering Instantcasino and eleven other casino sites to players in the Netherlands without a licence, the largest fine it has imposed for illegal gambling. The decision is dated 6 October 2026 and was announced on 22 October; it overtakes the €24,846,000 fine on Novatech, the company behind Qbet, which the Ksa decided in December 2025, announced in March and which Novatech is contesting. Read in full, the decision shows that the record was set by a legal ceiling: the Ksa's own calculation came to €292.6 million.

How €292.6 million became €37.25 million

Under its 2026 fining policy for illegal remote gambling, the Ksa sets the fine from the money the operator makes in the Netherlands. The starting point is the gross gaming revenue from Dutch players, the stakes kept after winnings are paid. EOD Code did not supply figures when asked on 26 May 2026, so the Ksa estimated them with its search-volume method, published on its website on 14 February 2025: it identifies the search terms that lead to the operator's sites, measures how often they are searched, and turns that volume into an estimate of gross gaming revenue for the Netherlands and for the whole business. Across the twelve sites, the decision then applies four steps:

The ceiling comes from article 35a of the Dutch Gambling Act, which caps a fine at 10% of the offender's turnover in the financial year before the decision when that is higher than the standard maximum. Because the Ksa applied it to worldwide revenue, the size of EOD Code's whole business, not only its Dutch play, set the limit. By our arithmetic the fine equals about 34% of what the Ksa estimates EOD Code won from Dutch players in 2025, and about 13% of the figure its own formula produced.

Eight reasons for 270 per cent

The 170 points come from a fixed table in the fining policy, and EOD Code collected eight of its entries. The two heaviest are the absence of visible age verification and what the Ksa called special circumstances: terms in the sites' general conditions that it considered unreasonable. Where the decision explains a factor, its reasons say a good deal about how the sites worked:

• Age verification (+50). A provider has to check a player's age visibly and adequately before registration is complete. Without it minors could get in, and the decision says EOD Code carried a particular responsibility to keep them out.
• Prohibited games (+20). An unlicensed operator can offer games that licence holders may not, which the Ksa says draws players away from the licensed market. The decision records casino games and sports bets on the sites but does not list the banned ones.
• Inactivity fees (+10). From the 13th month, €5 a month was deducted from dormant accounts. The Ksa calls this an impermissible disadvantage to the player, citing the Council of State, and says EOD Code could simply have closed the account and returned the balance.
• Payment in crypto (+10). The decision calls these "ongeoorloofde betaalmethodes", payment methods that are not allowed, because they can help tax evasion and money laundering.
• Autoplay or turbo play, missing or pre-filled play limits, and the size of deposits (+10 each) are listed with a reference to the investigation report, without further explanation in the decision.

The Ksa's announcement adds that visitors could also pay by anonymous payment methods, which with crypto, it said, makes money laundering easier.

The terms the Ksa called unreasonable

The special-circumstances finding rests on five clauses in EOD Code's general conditions. Read together they are a fair picture of what a player accepts at a site with no Dutch licence:

• a fee on withdrawing money that has not been wagered at least once (article 6.15);
• withdrawals capped at €4,000 a day, €10,000 a week and €20,000 a month (article 8.1);
• player balances that, although kept apart from the company's working funds, could still fall into its estate in a bankruptcy (article 6.5);
• no liability for unfair game results caused by technical faults (article 7.5);
• the right to keep a player's balance when the player asks for permanent self-exclusion (article 14.2).

Twelve sites, one company

The investigation began with Instantcasino. Further research, the Ksa says, found eleven more sites run by the same company: Skyhills, Slotmonster, Betiro, Betblast, Fastslots, Golden Panda, Samba Slots, Winningz, Incognito Casino, Foxygold and Luckypays. Ksa staff were able to play on several of them from the Netherlands, with no measures in place to stop Dutch players, on dates the decision lists between November 2024 and July 2026, the last on a numbered copy of the main domain. The decision records that the payment instructions were partly in Dutch. According to the sites themselves, EOD Code is registered and regulated in Costa Rica, with the courts of Curaçao given exclusive jurisdiction; it holds no Dutch licence.

Earlier orders, and what comes next

This is not the first decision against the company. The Ksa told the company on 10 April 2025 that it intended to impose an order subject to penalty payments, issued the order on 29 July 2025 and decided on 11 December 2025 to collect the penalties; EOD Code objected to none of these decisions, so they are final. Before the fine, the Ksa invited the company on 10 September 2026 to give its view, and EOD Code did not respond. We found no public statement from the company. It can lodge an objection with the Ksa within six weeks of the decision being sent, which was 7 October, but an objection does not suspend the fine; payment is due within the same six weeks. Whether the money can be collected from a company that never answered is another matter; the Ksa's announcement also points to its work with payment service providers, hosting companies, banks and large technology firms against illegal offers.

The fine sits beside the Ksa's other work against unlicensed sites. In March it announced its fine on Novatech, the company behind Qbet and 55Bet, which we covered in our report on the Curaçao licensing leak, and its chairman's argument with Google and Meta over illegal gambling ads is set out in our piece on the Ksa and big tech.

What is confirmed and what is not yet known

• Confirmed: a fine of €37,250,000 on EOD Code SRL, dated 6 October 2026 and announced on 22 October; twelve sites named; the Ksa's calculation of €292,600,000 cut to just under the legal maximum; earlier penalty orders final.
• Not yet known: whether EOD Code will object or go to court; whether the fine will be paid or collected; any statement from EOD Code.

What it means for players

None of the twelve sites holds a Dutch licence, and the decision shows what that can mean in practice: withdrawal caps, a fee for taking out unplayed money, and a clause that keeps your balance if you self-exclude for good. A licensed Dutch site has to keep player money separate and is supervised by the Ksa, which also runs an information line on working days from 9:00 to 13:00 on 070 302 13 00 (option 1). Our guide to casino licensing explains what different licences require.

Frequently asked questions

Sources

1. Kansspelautoriteit - Nieuwe recordboete illegaal kansspelaanbod opgelegd: 37 miljoen voor EOD Code (22 Oct 2026)
2. Kansspelautoriteit - Boetebesluit EOD Code SRL, case 20970 (6 Oct 2026)
3. Kansspelautoriteit - Decisions concerning EOD Code SRL
4. Kansspelautoriteit - Last onder dwangsom EOD Code SRL (29 Jul 2025)
5. Kansspelautoriteit - Invorderingsbesluit EOD Code SRL (11 Dec 2025)
6. NL Times (press) - Dutch Gambling Authority issues record 37 million euro fine (22 Oct 2026)