Nicolas Fleiderman, Holland Casino: The ‘structural imbalance’ exploited by black market advertisers

Nicolas Fleiderman, Holland Casino: The ‘structural imbalance’ exploited by black market advertisers

Dutch gambling is set for a seismic shift as the market prepares for a total ban on advertising and bonuses.

However, such a move must be ‘carefully balanced’ to avoid further emboldening the Netherlands’ surging black market, according to Holland Casino Online‘s General Manager, Nicolas Fleiderman.

Speaking to iGaming Expert ahead of appearing on a panel examining the ethical tension in gambling advertisements at the upcoming SBC Summit in Lisbon, Fleiderman shared his thoughts on how the ban will reshape the Dutch gambling market and examined the ‘structural imbalance’ caused by the black market being able to deploy social media tactics not available to licensed operators due to regulatory restrictions.

How will the proposed advertising and bonus bans impact the number of licensed operators?

The Dutch government has announced its intention to introduce a total ban on advertising and a full prohibition on bonuses, and expects to introduce a bill in the first quarter of 2027. The total ban is then expected to take effect in January 2028

These developments may lead to further consolidation in a market where that trend is already visible.

Smaller and mid-tier operators that rely heavily on paid acquisition and welcome offers are likely to see their primary growth levers restricted. Several have already indicated they may reassess their Dutch presence once the legislation is finalised.

Larger, brand-led operators – particularly those with a land-based presence – are generally better positioned to adapt, as their business models are less dependent on aggressive bonusing and more on brand recognition and customer trust.

So rather than simply fewer licences, the more likely outcome is a market concentrated around fewer, larger, and well-capitalised operators competing increasingly on product quality and reliability.

What impact will these changes have on the black market and channelisation?

This is arguably one of the most important questions for policymakers.

Channelisation in the Netherlands is, according to industry analyses and public discussions, estimated to be around 45–50% of gross gaming revenue. This is already relatively low compared to initial policy objectives.

Changes such as advertising and bonus restrictions may put further pressure on channelisation if not carefully balanced with enforcement and the attractiveness of the regulated offer.

Illegal operators typically do not apply player protection measures such as affordability checks, nor do they contribute to the broader duty of care within the regulated system.

The government has paired the proposed measures with increased enforcement capacity for the regulator, which is an important step. At the same time, enforcement against offshore or crypto-enabled operators remains complex and takes time to scale.

The key question is, therefore, how regulation and enforcement can continue to evolve together to safeguard players effectively and keep them within the regulated market.

How can operators balance promotions with maintaining appropriate player protection measures?

There is an inherent tension in the system, but it can be managed responsibly if promotions are designed with long-term player value and transparency at the core.

The tension typically arises when promotions are built for short-term acquisition rather than sustainable engagement. A promotion that hides complex requirements behind an attractive headline isn’t a player protection risk waiting to happen – it already is one, because it relies on confusion rather than informed choice.

The standard we apply is simple: would this offer still look fair if the player fully understood it before opting in? That’s why we’ve moved toward simpler mechanics with minimal conditions, because transparency is itself a form of protection.

The other key element is segmentation. A promotion that may be appropriate for a stable, recreational player is not appropriate for someone showing early signs of risky behaviour. Operators, therefore, need the monitoring infrastructure to make that distinction in real time, not after the fact.

How has social media changed advertising strategies, and what are the biggest challenges?

Social media has created a paradox. It gives operators highly targeted tools to reach relevant audiences, while at the same time weakening the link between regulatory frameworks and actual ad delivery.

The core challenge is that platform algorithms and self-regulation don’t align neatly with national licensing regimes. An operator can design a fully compliant campaign and still have limited control over who ultimately sees it.

At the same time, unlicensed operators can run forms of advertising that licensed operators are explicitly prohibited from using, often on the same platforms.

This creates a structural imbalance where compliant operators face limitations that are not always equally enforced across the broader ecosystem.

In the Dutch market, illegal advertising on platforms has become significant enough for operators to initiate legal steps and raise the issue at the European level. Addressing this requires cooperation between regulators, platforms, and operators to ensure that the same standards apply across the entire system.

What advertising strategies have proved most effective in driving player engagement?

In a market like the Netherlands, where untargeted advertising has been banned since 2023, and restrictions continue to tighten, ‘effective’ has taken on a different meaning.

We’re seeing stronger results from owned channels and product-led engagement than from traditional acquisition-driven media spend. Regulation has accelerated a shift that, in hindsight, also makes commercial sense.

Where the old model focused on reach and frequency, the better return today comes from building an experience players actively choose to return to.

In practice, that means investing in the product experience, using CRM in a behaviour-driven way rather than broadcasting to everyone, and optimising the existing-customer journey – which is also where regulation allows the most presence.

Channels that rely on broad reach and emotional triggers are becoming less viable by design. Ultimately, that’s pushing the industry toward strategies that look much more like retention marketing in other consumer sectors.

What can gambling learn from other entertainment industries in terms of advertising?

Streaming and subscription-based entertainment learned long ago that the product experience is the marketing.

Netflix doesn’t retain subscribers because of billboards, it does so through its recommendation engine and the strength of its content offering.

At the same time, gambling is fundamentally different from other forms of entertainment because of its risk profile, and that distinction should always remain clear.

That said, the broader lesson still applies: the strongest and most sustainable engagement comes from delivering a product that players genuinely value, not from constantly trying to reacquire their attention. Regulation is now pushing the sector further in that direction.

What are you most excited about at SBC Summit, and why do these events matter?

Honestly, the conversations outside the panels are just as valuable as those on stage. Across Europe, regulated markets are grappling with the same fundamental question: how to strengthen player protection without unintentionally driving players toward the black market. 

The Netherlands is currently one of the more advanced test cases in Europe for that balance.

Events like SBC Summit create space for open, practical exchange between operators, regulators, and suppliers — beyond the formalities of regulatory processes. That’s where the most useful insights tend to emerge.

I’m particularly interested in hearing how other tightly regulated markets — such as the UK, Italy, and the Nordics — are navigating similar challenges. The Netherlands doesn’t need to solve this in isolation, and the industry benefits when lessons are shared across borders rather than relearned one market at a time.


Held in Lisbon from 29 September to 1 October 2026, SBC Summit is one of the world’s largest gatherings of betting and gaming professionals.

The event will bring together 40,000 attendees from across the industry for three days of learning, networking, and discussion, alongside a major exhibition featuring leading brands from around the globe.

For more information and tickets, visit sbcevents.com/sbc-summit.

Source: iGaming Expert

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