The Kansspelautoriteit (KSA) announced that its investigation found several videos and live streams where Nedergaming played on HolyLuck through YouTube, Twitch, and Kick. The regulator also stated that Dutch players could easily create accounts, make deposits, and gamble on HolyLuck because there are no effective technical measures to block access to the site from the Netherlands.
Why the Regulator Treated the Streams as Promotion
The main point the KSA referred to was not just that the streamer used an unlicensed operator, but also that the content made the casino visible to the public. According to the regulator, the streams displayed the gambling interface on the screen and clearly revealed the platform’s name. In one case, an Excel file visible during the stream also showed the company name.
These circumstances were enough for the regulator to deem the activity a form of illegal gambling promotion. The KSA’s stance is that public gameplay may still generate interest in a prohibited operator, even if there are no affiliate links, discount codes, or instructions telling the viewer to join the platform.
This is an important point in relation to the wider market. What the authority is saying here is that promotion does not need to take a form which is obviously advertising to amount to a breach.
English-Language Defense Did Not Hold Up
Nedergaming argued that the streams were intended for an international audience and were conducted in English. However, this argument was dismissed by the KSA. According to the regulator, English-language content may still reach and influence Dutch viewers (and that’s especially true in a country where English fluency is high).
The regulator also pointed to references in the streams that indicated a connection to the Dutch market, including mentions of Albert Heijn and heksenkaas, a product strongly linked to the Dutch market. In the KSA’s view, it is not necessary for the content to be targeted at the Netherlands. It is enough that the country forms part of the intended or practical audience.
As the regulator also notes, there had been previous warnings to Nedergaming that promoting illegal gambling could result in enforcement action. On 2 February 2025, the streamer is said to have discussed the issue with the KSA in a Microsoft Teams call, and the rules were further explained to him.
What the Order Requires
The KSA has ordered Nedergaming to immediately stop the promotion of illegal online gambling. The streamer has five working days to remove existing content featuring such operators. The fine is set at €25,000 per violation, with a maximum of €75,000. The streamer can also face penalty payments for not deleting the content.
The removal of the videos may limit further exposure. A more significant implication, however, is that in the view of the Dutch regulator, gambling content is not simply evaluated by whether or not it contains a referral link. When a stream makes an illegal operator visible and helps normalize access to it, enforcement can follow.
