Dutch Regulator Flags Subscription Transparency

Dutch Regulator Flags Subscription Transparency

The Dutch gambling regulator has drawn attention to how lottery subscriptions are promoted in the Netherlands, following a sustained rise in consumer complaints. The authority has confirmed that it has entered discussions with several lottery providers after concluding that a significant number of consumers felt unclear about the commitments they were entering into when responding to certain promotional campaigns.

According to the regulator, the issue does not stem from the existence of subscription-based lottery products themselves, which are permitted under Dutch law. Instead, concerns have focused on how these subscriptions are introduced to potential customers and whether the information provided at the point of recruitment allows for informed decision-making. Over time, the KSA received repeated signals suggesting that this standard may not have been met consistently.

The complaints shared a common theme. Consumers reported believing they were accepting a free lottery ticket or participating in a one-off promotion, only to later discover they had agreed to a recurring subscription. In some cases, individuals said they believed they were making a charitable contribution or receiving a complimentary item, unaware that a paid arrangement would follow. These misunderstandings were not limited to a single outreach method but occurred across multiple channels.

The regulator noted that telephone-based recruitment, in-person promotions in public locations, and door-to-door campaigns were among the approaches cited by complainants. In each case, the KSA observed that the distinction between a single interaction and an ongoing financial obligation was not always clearly communicated. This lack of clarity prompted the authority to initiate direct conversations with lottery operators to assess how subscriptions are presented and explained.

During these discussions, several lottery providers acknowledged that aspects of their recruitment practices required revision. According to the KSA, some operators stated that they had already taken steps to improve transparency. These efforts reportedly included clearer explanations of subscription terms, more direct communication about recurring payments, and internal measures designed to reduce the risk of misunderstanding during sign-up.

The regulator has welcomed these commitments but has also indicated that progress across the sector has been uneven. While certain operators have implemented changes, others are still in the process of doing so. As a result, the KSA has made it clear that its engagement with the sector is ongoing rather than concluded. To determine whether stated improvements are reflected in practice, the authority plans to conduct inspections in early 2026.

These inspections will form part of a broader examination of recruitment practices used by lottery operators that rely on subscription models. The KSA has emphasised that transparency is a fundamental requirement for gambling products, particularly when financial obligations extend beyond a single transaction. Consumers must be able to understand what they are agreeing to without relying on assumptions or later clarification.

The regulator's approach suggests an effort to address the issue through dialogue before moving toward enforcement. No sanctions have been announced at this stage, and the KSA has framed its actions as preventative rather than punitive. However, it has also made clear that continued monitoring will take place and that further steps may follow if improvements are not sufficiently demonstrated.

From a regulatory perspective, the situation reflects a broader challenge associated with subscription-based models, which have become increasingly common across sectors. In the context of lotteries, subscriptions can offer convenience and continuity, but they also require a higher standard of communication. The KSA's position indicates that promotional messaging must reflect this reality, especially when initial contact suggests that participation is free or incidental.

For lottery providers, the regulator's message carries practical implications. Marketing strategies that rely on indirect language or implied benefits may no longer be considered acceptable if they obscure the nature of a subscription. Clear explanations of pricing, payment frequency, and cancellation options are likely to remain a focus of regulatory attention, particularly as inspections approach.

The volume of complaints received by the KSA suggests that the issue cannot be dismissed as isolated misunderstanding. Instead, the regulator views it as a systemic concern that requires consistent standards across the sector. By engaging operators collectively, the authority is signalling that transparency is not a matter of individual interpretation but a shared obligation.

As the review continues, the next phase will be shaped by whether lottery operators can demonstrate measurable changes in how they present subscriptions to consumers. The planned inspections in 2026 will serve as a benchmark for assessing whether dialogue has translated into practice. Until then, the KSA has indicated that it will remain attentive to consumer feedback and prepared to intervene if necessary.