The Dutch renewal cliff: why an exit plan belongs in a licence application

The Netherlands licensed its first online operators in September 2021 on five-year terms. Those licences expire in October 2026, which makes this the first renewal cycle the Dutch regime has ever run, and the Kansspelautoriteit has used it to add a requirement that deserves wider attention.

The exit plan

From 1 January 2026, applicants must file an exit plan setting out how they would halt operations in an orderly way if their licence were not renewed, alongside a risk analysis under the Dutch anti-money laundering and counter-terrorist financing act. The licence fee for a new remote permit rose from €48,000 to €61,300 from April 2026.

The exit plan is the interesting one, because it inverts the usual assumption. Licensing regimes are almost universally designed around entry: fit and proper tests, financial capacity, technical standards, all directed at deciding who may start. Very few ask the applicant to demonstrate that stopping can be done without harming anyone.

The riskiest moment in a licensed operator's life is not the day it opens. It is the day it is told it cannot continue, and still holds customer balances.

What an orderly exit has to solve

• Customer funds: segregation is meaningless if there is no tested procedure for returning balances to identified customers within a defined period.
• Self-exclusion continuity: a departing operator's exclusion records have to survive the operator, or every excluded customer is quietly released back into the market.
• Data and records: supervisory, AML and transaction records must remain reachable by the regulator after the entity that generated them has wound down.
• Customer communication: an operator with no future revenue has no commercial incentive to run a good wind-down, which is precisely why it has to be a licence condition rather than a request.

The KSA has widened the perimeter in the same period. Supervision now extends across the marketing chain, including agencies producing paid promotional content for unlicensed operators, which may be referred to the Netherlands Authority for Consumers and Markets. Payment providers, hosting companies, social media platforms and B2B game suppliers are all drawn further into scope.

Five years is long enough for a first cohort to have accumulated real customer liabilities. Ireland is running the same test from the other end. The Dutch regime is discovering, as every fixed-term regime eventually does, that the renewal cycle is where a licensing framework is actually tested.