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Kevin O’Neal, a DOCV board member, argued the scale of the investigation calls the GGL’s broader black market estimates into question. He cited the regulator’s 2025 activity report, which put the 2024 share at 23% (€547 million in gross gaming revenue), against Nielsen data suggesting a share of around 56%.

The trade body has long been critical over the discrepancy between channelisation estimates made by the regulator, and other independent reviewers.

The DOCV reinforced its calls for a unified federal licensing regime for online casino games and stronger enforcement mechanisms against illegal operators. 

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The triumvirate of Netherlands, Germany and Sweden is often held up as an example of how not to regulate, with all three countries haemorrhaging players to waiting illegal operators. So what is public sentiment like towards operators? “My feeling is that if you look at public sentiment, they don’t see really the difference between online and land-based,” says Petra. “If you look into what they’re saying, they’re primarily talking online. But for the general public, there is no difference [between the channels] in that respect.”

She believes the sentiment towards gambling among the Dutch public is comparable to the UK, Finland, Germany, France. “So, very tense,” she says.

However the sentiment towards the Holland Casino brand has remained quite positive, while more generally the sentiment towards gambling is very critical.

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The decision is not yet legally binding, with a further opportunity to appeal the denial of ‘leave to appeal’ open to the applicants. This will be reviewed by the Federal Administrative Court of Leipzig.

In his original complaint, Braun also cited a study that found that nearly half of respondents were thinking of using illegal gambling services due to legal restrictions. 

In recent weeks, German authorities conducted a crackdown on an alleged illegal online gambling operation suspected of facilitating wagers totalling approximately €5.86 billion over a 30-month period.