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KSA publishes Endorphina order over games on unlicensed sites

Endorphina disputes the regulator's account, saying its Maltese and Cypriot companies have separate distribution systems.

· 2 min read
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Key Points
KSA published on 2 November an instruction signed on 19 October against both supplier entities
Inspectors played Endorphina titles from Dutch IP addresses in checks continuing into September
Endorphina says it restricted access and contests responsibility for games on unlicensed platforms

The Dutch gambling regulator KSA has published a binding instruction to casino game supplier Endorphina after finding its titles playable on websites offering gambling in the Netherlands without a licence. 

The instruction was dated 19 October and released publicly on 2 November.

The order names Endorphina Limited in Malta and Endorphina Ltd. in Cyprus. Under Dutch gambling law, suppliers can be directed to stop facilitating unlicensed gambling even when they do not operate the gambling sites themselves.

KSA investigators using Dutch IP addresses played Endorphina games on a series of unlicensed websites during checks in January and February. Further checks took place in June and September. 

The regulator cited sites including Instantcasino, Luckygem and Winningz, and said it did not observe technical barriers preventing Dutch players from accessing the games.

Endorphina argued that its Maltese and Cypriot companies have separate licences, contracts and distribution systems. It said the Maltese entity supplies only Dutch-licensed operators and that games can reach websites through other business-to-business intermediaries. 

The supplier said it restricted access on sites named by KSA in July and strengthened arrangements with partners. It disputed that the presence of its games proved direct or deliberate supply to unlicensed operators.

KSA said the September checks still found Endorphina titles available on illegal Dutch-facing sites. It held that proof of intent was unnecessary for a binding instruction and ordered technical or contractual measures to prevent further access. 

The decision required the supplier to inform KSA of its response within two weeks of 19 October. The published documents do not state whether Endorphina met that deadline.

Endorphina also supplies licensed Dutch operators. In February, it announced a games agreement with Hommerson.nl, describing that operator as Dutch-licensed. Its Maltese company holds a business-to-business critical supply licence from the Malta Gaming Authority. 

The case fits KSA's wider focus on services that enable unlicensed gambling. Its latest market report estimated that 94% of Dutch online gamblers used only licensed sites in the first half of 2026, while licensed operators accounted for an estimated 59% of online gambling revenue. 

KSA said the gap suggests higher average losses among people using illegal sites.

On 22 October, KSA imposed a €37m fine on EOD Code over unlicensed online gambling. That case concerned a site operator, while the Endorphina instruction addresses a supplier's distribution controls.

Good to know

Endorphina may object to the instruction, but doing so does not automatically suspend the decision

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