KSA puts slot studio Endorphina on notice

• The KSA issues a binding instruction to Endorphina’s Malta and Cyprus entities.
• Inspectors played Endorphina slots on 27 unlicensed sites between January and September.
• The regulator rejects the argument that the two entities operate separately.

The Netherlands Gambling Authority (KSA) has ordered slot studio Endorphina to stop Dutch players reaching its games on unlicensed casinos.

The binding instruction, signed on 19 October and published on 2 November, gave the supplier two weeks to act and report back.

Twenty-seven sites, one logo

The order is addressed to Endorphina Limited in Malta and Endorphina Ltd in Cyprus. The KSA found that neither had taken adequate measures to keep its games off sites operating without a Dutch licence.

The legal basis is Article 1(1)(b) of the Betting and Gaming Act, which bans promoting participation in unlicensed gambling. The KSA’s position is that supplying games to an unlicensed operator is promotion under that article.

Inspectors logged in from Dutch IP addresses in January and February, again in June, and on 29 and 30 September. The final round covered eight unlicensed sites with substantial Dutch traffic, including Winningz, Wizebets, Playboom24 and Betplay.io.

The decision names 28 unlicensed domains and records Endorphina game sessions at 27 of them. Hell Hot 100 appeared in six of the 41 logged sessions, more than any other title. Lucky Streak 3, Cockroach Fortune and 2025 Hitslot each appeared twice.

The KSA said it saw no technical measures stopping Dutch players. Endorphina’s logo loaded with each game, its name appeared in the game URL and it was shown under every title.

Sanctioned sites, still spinning

Several domains were already known to the regulator. The operators of qbet.com and luckygem.com had both received KSA penalty payment orders, luckygem’s on 15 September. Endorphina games were still playable on both in late September.

Qbet was also the subject of a black market lawsuit brought by Nederlandse Loterij in April.

Seven more sites in the file belong to the network run by EOD Code SRL, which the KSA hit with a record €37.25 million fine in October. They are Instantcasino, Betiro, Betblast, Fastslots, Goldenpanda, Sambaslots and Winningz.

Results that never arrived

The KSA first contacted Endorphina on 2 April through the contact form on its website. It sent its findings on 15 April, and the two sides met on 16 April. Endorphina said it could explain the findings within a week.

On 29 April, the regulator sent its list of licensed Dutch operators and asked for that explanation. On 7 May, Endorphina said it was still investigating and could not share everything because of contractual confidentiality.

On 14 May, the studio said there was no evidence it had intentionally supplied illegal operators. On 1 June, it declined a further meeting because of the summer period and asked for the KSA’s position in writing. The regulator replied that it had already explained its view several times and that formal measures would follow.

Endorphina’s 5 June response described a robust compliance framework. Games are certified for the Dutch market, it said, and licences are checked before distribution. It added that its content also reaches sites through licensed B2B intermediaries, so a visible Endorphina game does not prove direct supply.

The KSA asked several times for the results of Endorphina’s internal investigation. It never received them and said it could not take them into account.

Malta, Cyprus, same reply

The KSA notified the Maltese company of its intention to issue the instruction on 14 July, and the Cypriot company on 9 September.

Both responses argued that the two companies have separate licences, contracts, distribution channels and remote gaming servers. Endorphina Malta, the studio said, supplies the Dutch market only to licensed operators and checks their status against KSA records.

Endorphina also said it restricted access to its games on all named sites in July and tightened agreements with partners. It said these steps were preventive and not an admission of a breach.

The KSA rejected the argument. The two submissions were identical and came from the same contact person. The regulator said Endorphina had not consistently mentioned the split in its contacts between April and July, and that the separation is not visible on Endorphina’s own website.

Why intent did not matter

A binding instruction can be used where a breach exists but a sanction is not yet appropriate. The KSA said this covers a supplier that provides essential services to illegal operators without knowing it.

That made two of Endorphina’s arguments irrelevant: whether supply was intentional, and which entity handled it. Both companies, the KSA said, appear able to stop Dutch players reaching the games. The compliance framework also carried no weight, because it had not prevented access.

The regulator accepted that distribution errors or third-party misuse could put Endorphina’s name on illegal sites. That is why it wanted the investigation results. It also said a company with a registered trademark can be expected to take legal action against misuse, and Endorphina had shown no sign of doing so.

The KSA added that preventing games appearing on unlicensed sites does not require extensive or complex technical work. Its September checks found Endorphina titles still live on illegal sites, two months after the July measures.

What comes next

The two-week deadline ran out on 2 November, the day the decision was published. By then Endorphina had to have its measures in place and to have told the KSA what it had done. The regulator has not said publicly whether it has received that report.

Complying is a legal obligation. Under the explanatory memorandum to the Remote Gambling Act, breaching a binding instruction can be fined under Article 35a of the Betting and Gaming Act. That applies where the KSA has good reason to believe the company did not make enough effort to comply.

The ceiling is high. According to the KSA, an administrative fine can reach the Dutch Criminal Code’s sixth-category maximum or 10% of turnover in the previous financial year, whichever is higher. The regulator can also impose penalty payment orders, which build up until a breach ends.

Endorphina has already been warned that this route exists. On 13 May, the KSA told the studio that enforcement could follow if it did not provide the information discussed.

Where suppliers now stand

For other studios, the decision spells out what the KSA expects. It says Endorphina can comply through technical measures in its own operations and through contract terms with customers and distributors. Those terms should stop Dutch players reaching its games on unlicensed sites.

The KSA publishes its register of licensed operators and its sanctions decisions. It shared both with Endorphina, and it cites that in the decision. A studio that has received the list cannot easily say it did not know which Dutch-facing sites were unlicensed.

The case also shows how the KSA weighs a supplier’s conduct. It noted that Endorphina had been informed repeatedly and had not acted adequately. Delays, partial answers and a declined meeting all appear in the published record.

Studios under scrutiny

The decision frames suppliers as intermediaries, alongside payment and internet service providers. The KSA said it targets these to make unlicensed offers harder to run, and game content is now part of that approach.

In the UK, Evolution agreed a £4.75 million settlement with the Gambling Commission after its content reached unlicensed sites. The legal mechanisms differ, but in both markets the supplier answered for where its games ended up.

The KSA estimates that channelisation by gross gaming result reached 59% in H1 2026, up from 54%. Studios licensed in the Netherlands and supplying offshore brands through aggregators now have a published example of how the KSA will test their controls.