Calling players in the Netherlands: KSA rules and Cruks

Most guides to Dutch gambling marketing cover the 2023 ban on untargeted advertising: TV, billboards, sponsorship. Calling players in the Netherlands barely gets a mention, even though a call is the most personal approach an operator can make, and the place where the Koa's targeting, bonus and duty-of-care rules all land at once.

This guide covers the rules that apply to an outbound call from a licence holder under the Wet kansspelen op afstand (Koa), in the order you hit them when you plan a campaign: who you may call, who you must not call, what the call may offer, and what it must do when something sounds wrong.

The rulebook for calling players in the Netherlands, in one table

The Koa came into force on 1 April 2021 and the legal online market opened on 1 October 2021. It amended the Wet op de kansspelen (Wok) rather than replacing it, so the rules for a marketing call come from three places:

Step one: players agree to calls when they sign up

The cleanest basis for a phone campaign is one the player set up themselves. At registration, ask a clear question about phone contact on its own: a separate box, not folded into the terms and conditions or a general "marketing" tick, saying that your brand may phone them with offers and news about their account. Leave it unticked. A player who ticks it knows a call may come, so the call doesn't arrive as a surprise, and you can show exactly what they agreed to.

Record each opt-in properly:

• the date and time the player gave it
• the exact wording shown at that moment, versioned, so you can show what someone who signed up two years ago actually saw
• the channel (website or app) and the phone number it applies to

What this means for a reactivation list:

• A general marketing tick box that never mentioned phone calls is not a phone opt-in. Check the wording your players actually saw.
• Players who registered before you added the phone option can be asked by email or in the app. Until they say yes, they stay off the call list.
• Make withdrawal as easy as the opt-in: in account settings, in every email and on the call itself.
• Service calls (a failed deposit, a verification document, a limit question) are a different kind of call. Keep them free of offers: once the agent mentions a bonus, it's a marketing call and everything below applies.

The gambling decree adds its own layer. Article 3(3) of the Bwrvk allows personally approaching consumers unless the consumer has told the operator, or a designated register, that they don't want it. In practice that means every "stop calling me" has to suppress the number across every campaign, not just the one that heard it.

Step two: the people you must not call

Article 2 of the Bwrvk sets out who your marketing may not be aimed at. Paragraph 3 covers socially vulnerable groups, which explicitly include minors and people showing signs of risky gambling. Paragraph 4 adds two groups for online licence holders: people aged 18 to 24, and people who have excluded themselves from your games.

For an online operator, Article 2ab also requires that targeted marketing reaches none of those people. The KSA's guidance on online channels says operators must show that at least 95% of the people an advertisement reached were 24 or older. A call list is the easiest place to meet that standard: you know every person's date of birth, so filter out under-24s completely rather than aiming for 95%.

The Cruks problem

Cruks (Centraal Register Uitsluiting Kansspelen) is the national self-exclusion register the KSA keeps under Article 33h of the Wok. A registration lasts at least six months. You would expect to screen your call list against it. You can't.

In a parliamentary answer of 4 May 2026, the state secretary for Justice and Security agreed that approaching Cruks registrants actively is incompatible with the Wok, then explained the catch: under Article 33h, operators may consult Cruks only to admit players to the venue or the gaming interface, which means operators are not allowed to check whether someone is registered in Cruks when sending marketing. The answer calls this problematic and says a law change is being drafted.

Until it is, the practical defence is your own data:

1. 1

   Exclude anyone blocked at their last login

   Your platform checks Cruks when a player logs in. If a login attempt was refused because of a Cruks hit, flag that account as excluded from every marketing channel, and keep the flag until a later login succeeds.

2. 2

   Exclude every internal exclusion and cool-off

   Players who excluded themselves with you directly, players you advised to register in Cruks, and players you reported to the KSA under Article 31m all come off the list.

3. 3

   Exclude open harm signals

   Article 13 of the Bwrvk already makes you record internal and external signals of excessive play. Anyone with an open signal, or an intervention still running, is not a marketing target.

4. 4

   Exclude under-24s outright

   Filter on date of birth, not on a segment label someone set a year ago.

5. 5

   Re-check the list on the day you dial

   Exclusions happen every day. A list exported on Monday and called on Thursday is three days stale. Re-run the filters immediately before upload.

Our self-exclusion registers reference tracks the same gap alongside GAMSTOP, Spelpaus, ROFUS and the German OASIS file, with the source for each rule.

Step three: what the call may offer

Most reactivation calls carry a bonus. Article 2a of the Bwrvk is short and strict, and operators often miss parts of it:

• No bonus during play, and none within a set period after you have intervened in a player's gambling under Article 18.
• No bonus tailored to individual behaviour. Paragraph 2 says the operator does not tailor the moment it offers a bonus, or the nature of the bonus, to the player's individual gambling behaviour. That sits awkwardly with "we noticed you stopped playing blackjack, here are 50 free spins." Ask your compliance team how they read it before you build offers around play history.
• Clear terms, explicitly accepted. The player must be told the bonus terms and payout conditions clearly, and you may not credit a bonus the player has not expressly accepted.
• A standing way out. Players must be able to say at any time that they no longer want bonuses.

Article 4a of the Wok adds that marketing must not be misleading, must not suggest the consumer has already won, and may not use personal data collected for a different type of licensed game. Lottery data doesn't go into a casino call list.

On a call, the safe pattern is: present the offer once, in plain words, give the conditions whenever asked, and record a clear "yes" before anything is credited. That's how Dial Milo handles offers: you write the offer and its exact terms, Milo presents it once, never invents or changes a term, and gives the deposit or wagering conditions when the player asks. Whether an offer is lawful in the first place is your decision, not the call agent's. More on structuring the offer in casino bonus offer calls.

Step four: duty of care on the call itself

The Dutch duty of care is not just a list filter. Article 31m of the Wok makes online operators register and analyse play systematically and, when they reasonably suspect excessive play, investigate it in a personal conversation with the player. Article 18 of the Bwrvk lists what that conversation must cover: the player's behaviour, the dangers of addiction, the tools that limit play, and the help available.

A reactivation call is not that conversation, and it must never pretend to be. But it can surface the same signals. A player who says they stopped because they lost too much, or who asks whether the bonus can cover a debt, has told you something your duty of care already obliges you to act on.

In March 2026 the KSA published guidance on the personal conversation and on Cruks notifications: if serious signals appear, advise the player to register in Cruks, and if they don't, notify the KSA. So a marketing call needs a hard exit:

1. Stop the offer at the first sign of harm. Don't finish the pitch and don't "just mention" the terms.
2. Give the help information you would give in any other channel.
3. Flag the player for your safer-gambling team so the follow-up happens under your Article 18 process.
4. Put the number on the do-not-call list for every campaign.

Dial Milo does steps 1, 2 and 4 on its own: at any sign of harm it stops selling, flags the player for your team and suppresses the number. Step 3 belongs to your team. The flag reaches them under Needs your attention in the dashboard and, if you use Customer.io, as the milo_safer_gambling_flag attribute on the player. More on scripting this in safer gambling outbound calls.

The October 2024 rules show how far the KSA expects player contact to go. New players get a monthly deposit limit of at most €350, or €150 for players under 24, and raising it requires a mandatory personal contact moment that covers the risks and points to Cruks. Above €700 a month (€300 for young adults), operators must check affordability. These are service conversations, and they are often better candidates for a phone call than reactivation is.

What a compliant Dutch call sounds like

Worked example. The player ticked the phone opt-in when registering in March 2025, is 31, has no open signals and logged in successfully last week. The campaign passes language nl.

Milo: Goedemiddag, je spreekt met Milo, een AI-assistent. Spreek ik met Daan?

Player: Ja, dat ben ik.

Milo: Fijn. Ik bel namens [merk], omdat je hebt aangegeven dat we je telefonisch mogen benaderen. We hebben een aanbod voor je: [het aanbod, letterlijk zoals de operator het heeft geschreven]. Wil je de voorwaarden horen?

Player: Nee, eigenlijk wil ik niet meer gebeld worden.

Milo: Begrepen, dan bellen we je niet meer. Fijne dag nog.

The brand name only comes after the identity check, so a partner or flatmate who picks up learns nothing. The AI disclosure comes first. The opt-out is accepted straight away, without a second pitch, and it's recorded as an opt-out outcome that suppresses the number across campaigns. If the player had answered in English, Milo would have switched to English.

The changes coming next

Plan campaigns knowing the rules are about to tighten. In a letter to parliament of 12 June 2026, the state secretary set out the next Wok amendment:

• A ban on advertising for online gambling. The letter counts offering bonuses as advertising too, and says bonuses will be included in the ban. The only exceptions currently foreseen are the operator's own website and advertising shown for explicit searches for gambling sites.
• A stronger duty of care, plus a review of how many online licences there should be.
• Six improvements to Cruks, including stopping registrants from being shown marketing.
• Timing: the aim is to have the consultation version of the bill ready in the first half of 2027. Nothing in it applies yet.

If outbound bonus calls fall within that ban once it passes, the phone use that survives in the Netherlands will be the service and duty-of-care calls described above. A campaign set up today should be able to run as a pure service call, with no offer field, without rebuilding anything.

A pre-call checklist for Dutch campaigns

Players also call back: in a pilot we ran with an online casino operator, players rang the campaign number hours after a missed call. Make sure a returned call gets the same identity check, so the brand isn't named to whoever dials in. Dial Milo recognises returning players and gives unknown callers a neutral line.

For the bigger picture across markets, the player reactivation guide covers segmentation, offers and measurement, and is it legal to make AI calls covers AI-specific disclosure rules in the US, UK and EU.