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Netherlands dismisses Polymarket’s administrative appeal

Manfredi Bertelli
Written by Manfredi Bertelli

The Kansspelautoriteit (KSA), the Dutch authority responsible for regulating and supervising the gambling market, has dismissed the administrative appeal lodged by Adventure One QSS Inc., the company operating under the Polymarket brand, against the measure adopted by the Dutch regulator earlier this year. Both the order to cease the unauthorised offering and the decision to make the proceedings public therefore remain in force.

The KSA made the decision on 23 June 2026 and published it on 8 July. It confirmed the order announced in February, telling Polymarket to stop operating in the Netherlands without authorisation. The decision came from the regulator, not a court.

KSA considers prediction markets to be gambling

In its decision, the Dutch regulator reiterated that Polymarket’s prediction markets fall within the definition of gambling under Dutch law. Users can stake money on the outcomes of future events over which they cannot exercise decisive influence, with the possibility of receiving a financial return.

The KSA also noted that the fact that users trade with one another, rather than against the house, is not sufficient to exclude the application of gambling legislation. According to the regulator, the operator’s apparently limited or technical role also does not remove its responsibility for providing the infrastructure through which users can participate.

The authority also distinguished between sports betting, which may be offered in the Netherlands by licensed operators, and betting on non-sporting events. The latter includes, for example, predictions on political outcomes or other future events and cannot be offered under a standard Dutch remote gambling licence.

January order upheld

The case stems from the order of 20 January 2026, by which the KSA imposed a ‘last onder dwangsom’ on Adventure One – that is, an administrative order accompanied by a financial penalty in the event of non-compliance. In the decision adopted on 23 June 2026 and subsequently published by the KSA, the authority confirmed the validity of the order and rejected the main objections raised by the company.

According to the KSA, Polymarket allowed users in the Netherlands to participate in online games and betting without the authorisation required under national law. The measure was published on 17 February 2026, which was also the deadline given to the company to cease the disputed activity.

On 18 February, the Dutch regulator carried out a further inspection and concluded that the infringement had not been fully remedied. Adventure One subsequently filed an objection in early March, seeking the annulment of both the order and the related publication decision.

Separately, the KSA determined that a penalty of €420,000 had become payable. The amount resulted from the company’s failure to comply with the January administrative order within the required timeframe. It is therefore not a separate new fine, but the amount accrued under the mechanism provided for by the last onder dwangsom. On 19 May, the authority adopted a specific decision to proceed with the collection of the amount.

Polymarket’s position

In its appeal, Adventure One challenged several aspects of the measure. The company argued that Polymarket should not be regarded as a traditional gambling operator because the platform allows users to buy and sell positions on the outcome of future events through a blockchain-based protocol.

Under this interpretation, Polymarket would act primarily as a technical interface, without betting directly against users, setting odds, or managing a central prize pool. The company also disputed that the service was directed at the Dutch market and questioned its direct responsibility for activity carried out through the platform.

The KSA rejected these arguments. In the authority’s view, neither the way the service is structured nor the technology used changes the nature of the activity offered to users.

Possibility of a further appeal

The KSA declared the objections against the 20 January order and its publication unfounded, upholding both measures. The objection to the notification that the penalty had become payable was declared inadmissible. The authority also rejected Adventure One’s request for reimbursement of its costs.

However, the case is not necessarily over. The company may still appeal the decision before the competent administrative court within six weeks of notification of the decision. Any legal appeal would not automatically suspend the effect of the measure, which therefore remains valid unless the court decides otherwise.

This article was originally published on the Italian SiGMA News page on 10 July 2026.

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