Exit plan required for Dutch iGaming licences expiring in 2027
KSA requires an exit plan in every application starting 1 Jan 2026
Key Takeaways
- The Kansspelautoriteit requires a formal exit plan in every remote gambling licence application from 1 January 2026.
- Operators with licences expiring in 2027 must include an exit plan when applying for a follow-up licence.
- Exit plans must address player protection and refunds, financial and contractual obligations, data retention, communications and operational execution.
- Player funds protection mechanisms help refunds but do not replace the broader legal, technical and organisational elements the KSA requires.
- EM Group’s Amsterdam team offers assistance reviewing exit plans, player funds schemes and compliance frameworks.
The Kansspelautoriteit introduced a formal requirement to submit an exit plan in all remote gambling licence applications from 1 January 2026, including applications from existing licence-holders seeking a follow-up licence. For operators whose current licence expires in 2027, the requirement is already relevant and preparation should begin in good time.
What the Dutch rules require from 2026
From 1 January 2026, all applications and re-applications for a remote gambling licence in the Netherlands must include a detailed exit plan as part of the filing. The Kansspelautoriteit (KSA) treats this not as a simple renewal: incumbent holders must apply for a new licence through the designated procedure.
The exit plan must set out how the operator would carry out an orderly termination of its gambling activities in different scenarios, including licence expiry or termination and the decision to cease offering gambling services.
Minimum content an Exit Plan must show
A credible plan needs to cover legal, financial, tax, organisational, technical and communications aspects. It must be practical, sufficiently detailed and consistent with the operator’s actual business model. Key points the KSA expects to see are:
Player protection and refunds: how outstanding player balances would be identified and refunded, and how cases where refunds are problematic would be handled.
Financial and contractual obligations: how outstanding obligations would be met and how contracts with suppliers and payment service providers would be terminated.
Communication and accessibility: how former players and the KSA can contact the operator during the wind-down, including the appointment of an appropriate contact person.
Data retention and audit trail: how relevant records and logs will remain available, secure and accessible and how applicable retention, archiving and transfer rules will be observed.
Operational execution: internal coordination of the closure, responsibilities, timelines and measures needed to meet outstanding obligations.
These elements must be integrated into a single coherent plan, not treated as isolated checklist items.
Player funds protection and practical operations
Player funds protection is an important component of the exit plan. An appropriate safeguarding mechanism can facilitate refunds if activities cease, but the plan must also address practical operations: access to funds, balance reconciliation, payment processes, contractual dependencies and availability of records.
The rules do not remove the need to assess whether a legal protection structure for funds works in practice. Operators must verify that agreements permit effective access to resources and reconciliations in a closure scenario.
Early preparation and professional support
For licences expiring in 2027, the practical recommendation is to integrate exit planning into overall application preparation and regulatory compliance rather than leaving it to the final months before filing. EM Group offers to review the relationship between exit plans, player funds protection schemes and an operator’s operational and compliance frameworks; its team in Amsterdam is available to assist in preparing the plan.
Frequently asked questions and closing considerations
The obligation to file an exit plan applies to all applications from 1 January 2026 and therefore to re-applications by incumbent holders. Starting preparation early allows identification of gaps and coordination with player funds protection, contractual obligations and operational processes.
Frequently Asked Questions
Since when is an exit plan mandatory in the Netherlands?
The obligation is effective from 1 January 2026. All applications and re-applications for remote gambling licences submitted from that date must include an exit plan.
Does the requirement apply to operators whose licence expires in 2027?
Yes. Operators with licences that expire in 2027 must prepare an exit plan because the KSA requires this document in follow-up licence applications from 1 January 2026.
What must an exit plan demonstrate specifically?
The plan must detail how player funds and refunds would be managed, how financial and contractual obligations would be met, how communications with former players and the KSA would be handled, how data retention and audit trails will be preserved, and the operational execution with responsibilities and timelines.
Does a player funds protection foundation replace the exit plan?
No. A funds protection mechanism can support player protection but does not substitute for the exit plan or its other legal, technical and organisational elements required by the KSA.
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About the author
Miguel Sandoval
Regulatory Affairs Correspondent
Miguel Sandoval tracks gambling legislation, licensing, and regulator enforcement — from Spain's DGOJ and the Latin American authorities to the UKGC, the MGA, and the state-by-state map in North America. The reports answer three questions precisely — what changed, where, and who it affects — with jurisdictions, dates, and penalties cited exactly as published. Operators and compliance officers read Miguel Sandoval to know which rulebook moved before their next meeting.
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