Dutch iGaming Applicants Must Submit Exit Plans from 1 January 2026

Operators applying for a Dutch remote gambling licence must include a formal exit plan from 1 January 2026. The requirement applies to new applications and to existing licence holders submitting applications for a follow‑up licence; for operators whose current licence expires in 2027, exit planning is already a live compliance task.

What changed in Dutch licensing

The Kansspelautoriteit (KSA) altered its licensing procedure so that re‑application is not a simple renewal process but a fresh application under the updated rules. From 1 January 2026 every application and re‑application for a Dutch remote gambling licence must contain a credible exit plan. The KSA will assess that plan alongside other licensing criteria.

Operators with licences expiring in 2027 are therefore advised to make exit planning part of their broader licensing and compliance preparation rather than postponing it to the final months before filing. Preparing in advance allows time to map existing arrangements, identify gaps and ensure the plan reflects operational reality.

What an exit plan must demonstrate

A credible exit plan must set out how the operator would wind down gambling activities in an orderly way and address legal, financial, tax, organisational, technical and communication aspects. The plan should be practical, sufficiently detailed and consistent with the operator's actual business model. Key elements the KSA will expect to see include:

• Player protection and repayments: how outstanding player balances would be identified and repaid, including handling cases where repayment proves difficult.

• Financial and contractual obligations: how outstanding liabilities would be met and how supplier and payment‑processing arrangements would be terminated or transferred.

• Communication and accessibility: how former players and the Kansspelautoriteit would remain able to contact the operator during the wind‑down, and the designation of an appropriate contact person.

• Data retention and the control database: how records will remain available, secure and accessible, and how retention, archiving and transfer requirements will be met.

• Operational execution: coordination across the organisation, with responsibilities, timelines and measures needed to fulfil outstanding obligations.

These parts must interlock as a coherent, implementable plan that covers different exit scenarios, including licence expiry or voluntary cessation of gambling activity.

Player‑funds protection and practical access

Player‑funds protection is a core component but does not replace the exit plan. Operators must explain how player balances are safeguarded and how those funds would be made available for repayment if activities ceased. The plan should assess practical factors: access to safeguarded funds, reconciliation of player balances, payment processes, contractual dependencies and the availability of relevant records. Where payment and safeguarding arrangements are relied on, documentation should demonstrate they will operate effectively during an exit.

Operators frequently link exit planning to player‑funds protection and to broader licensing and compliance preparation. Advice and review services are available from market advisers; the source article notes that EM Group can assist operators in reviewing how exit plans, player‑funds arrangements and operational compliance interrelate.

Why start preparing now

An exit plan is no longer a formality for departing operators; it is a mandatory element of every licence application submitted from 1 January 2026. For licences expiring in 2027, building the exit plan well ahead of the application window gives time to coordinate contractual, technical and financial actions and to ensure documentation matches how the business actually operates.

For operators seeking external support, the article referenced a team based in Amsterdam that can help prepare or review exit plans and associated safeguards. The KSA will expect the exit plan to be both credible and demonstrably implementable when submitted.