The Netherlands Gambling Authority (KSA) has issued a binding instruction to Endorphina Limited in Malta and Endorphina Ltd. in Cyprus after finding the supplier’s games available on unlicensed gambling websites accessible from the Netherlands.
The Kansspelautoriteit published the October 19 decision on November 2. Endorphina was given two weeks to take measures preventing its content from appearing on illegal Dutch-facing sites.
The instruction does not include an immediate fine, although sanctions may follow if the regulator concludes that the supplier has failed to comply.
The KSA based its action on provisions of the Dutch Gambling Act that prohibit promoting participation in unlicensed gambling and allow the authority to issue binding instructions to intermediaries that supply essential components of remote gambling services.
KSA Documents Games on Unlicensed Websites
KSA inspectors used Dutch IP addresses to access Endorphina titles on websites without Dutch licences between January 12 and February 19, 2026.
The regulator documented 15 instances involving games such as Hell Hot 100, Royal X-mass, Bad Santa, Wild Love, Thunder Crown and Fortune Snake.
The titles appeared on operators including Starzino, Amonbet, Holyluck, Chacha.bet, Luckygem, Spinstar.bet and Justbit.io.
As reported by Pimlico Solutions, other games identified during the checks included Cockroach Fortune, 3 Royal Dracos, Sushi, Royal Xmass 2 Dice, Lucky Streak 3 and Lucky Cloverland.
The regulator said it observed no technical measures preventing Dutch players from accessing the games.
Endorphina was notified of the findings in April. Follow-up checks took place in June and later in the year, with the supplied material stating that its games remained playable on unlicensed websites as late as September 30.
Across the wider investigation, Endorphina titles were reportedly found on at least 28 unlicensed sites.
Some operators involved have already faced separate enforcement. The KSA ordered action against Spinstar and Luckygem, while EOD Code SRL was fined €37.25 million for offering unlicensed online gambling in the Netherlands.
Endorphina Challenges Scope of Instruction
Endorphina has questioned whether the regulator can establish which of its two legal entities supplied the games found on illegal sites.
The company operates through businesses in Malta and Cyprus. Endorphina Malta serves the regulated Dutch market and has argued that the instruction should not automatically apply to that entity.
The KSA rejected that argument, calling the distinction “irrelevant for the purposes of this binding instruction.”
The regulator said both entities appear capable of taking steps to prevent the games from reaching unauthorised operators serving Dutch customers.
Endorphina has also maintained that there is no evidence it “intentionally supplied games to illegal providers in the Netherlands.”
The company has pointed to B2B intermediaries as a possible route through which its titles reached those websites.
The KSA said Endorphina had indicated it would investigate third-party misuse of its content, but requested findings from that internal review were not provided in time to form part of the regulator’s decision.
Decision Expands Pressure on Suppliers
The case shows the KSA applying enforcement beyond operators that directly accept wagers.
Its position is that a game supplier can fall within Dutch enforcement powers when its products form an essential part of an illegal gambling service.
The regulator also said publication of the instruction serves a preventive purpose. Games appearing on both licensed and unlicensed websites may give consumers the impression that an illegal platform is legitimate.
The decision therefore places greater responsibility on suppliers to monitor where their content is distributed and respond when regulators identify unauthorised availability.
Endorphina may lodge an objection within six weeks, although doing so does not automatically suspend the instruction.
The case adds another layer to the KSA’s enforcement strategy by targeting the gambling supply chain alongside operators themselves.