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Written and checked by Marnix OosterhuisEditor

Where a dispute ends up when there is no Dutch licence

A complaint about an online casino runs past fixed stations. Which stations there are depends on the licence — and with operators outside the KSA register, stations fall away that most people silently assume are there.

De reiger-registerhouder van dichtbij, de figuur van deze site

What the operators put on paper themselves: the name they trade under, the licence they cite, the cap that applies to a withdrawal and the amount above which they ask for documents. Behind every figure stands the clause it comes from. An empty field means the operator publishes nothing about it or that we could not read it — it is not a zero and not an ‘unlimited’. None of the ten appears in the licence register of the Kansspelautoriteit, the Dutch gambling regulator.

Vaveour partner
Operating company
TechOptions Group B.V.
Licence
Curaçao no number
Withdrawal cap
from 50.000 USDT in instalments art. 8.8
Documents from
case by case
Bitcasino.io
Operating company
Moon Technologies B.V.
Licence
Curaçao Gaming Authority
Withdrawal cap
1.000.000 USDT per week art. 6.10
Documents from
2.500 EUR
Empire.io
Operating company
Pixel Entertainment Limited
Licence
Anjouan Gaming Board licence excludes NL
Withdrawal cap
not published
Documents from
2.000 USDT
Bitsler
Operating company
Oyine N.V.
Licence
Curaçao Gaming Authority
Withdrawal cap
not published
Documents from
not published
Cloudbet
Operating company
Halcyon Super Holdings B.V.
Licence
Curaçao Gaming Authority
Withdrawal cap
not published
Documents from
not published
CoinCasino
Operating company
Igloo Ventures SRL
Licence
Anjouan Gaming Board licence excludes NL
Withdrawal cap
500.000 EUR per month art. 9.6
Documents from
not published
Rakebit
Operating company
Nile King Media Ltd
Licence
Anjouan Gaming Board licence excludes NL
Withdrawal cap
not published
Documents from
not published
Primedice
Operating company
Antillephone
Licence
Government of Curaçao
Withdrawal cap
not published
Documents from
not published
Stake
Operating company
Medium Rare N.V.
Licence
Curaçao Gaming Authority
Withdrawal cap
not published
Documents from
not published
BetPlays
Operating company
not published
Licence
not published
Withdrawal cap
5.000 EUR per week art. 6.11
Documents from
not published

The question that gets asked too late

Almost nobody looks, before opening an account, at where they would have to file a complaint. That is human: you do not open an account with the thought that it will go wrong. The consequence, though, is that the question is only asked at the worst moment, namely when money is already involved and the other party has already stopped replying.

This page sets out the stations in the order they run in this subject. It is written for the situation that occurs most often: a payout that does not come through, or an account that is blocked while there is a balance on it.

Station one: the operator itself

Every complaint route begins with the operator, and that is not merely a formality. The general terms and conditions nearly always contain a procedure with deadlines in it, and that procedure is the basis you can fall back on later with anyone at all.

Two things are worth doing here. The first is working in writing and keeping it: chats disappear, e-mail stays. The second is looking up the clause number to go with it. Anyone who invokes "article 6.10" instead of "you should have paid out" stands stronger, even with an operator that would rather not read its own terms.

For some operators in this overview that clause number is known. Bitcasino.io names a cap of one million USDT per week in article 6.10 and a verification limit of 2,500 euros in article 6.6. CoinCasino names half a million euros per month in article 9.6 and describes the checks in articles 5.2 and 9.3. BetPlays names five thousand euros per week in article 6.11 and the checks in article 4.3. Empire.io names a limit of 2,000 USDT in article 5.4. Bitsler points to article 4.3, Cloudbet to article 18.1.1 and Stake to article 4.8.

For other operators that number is not there. At Rakebit and Primedice we did find the check clause but could not establish a clause number. At Vave we were unable to read any terms at all — a particularly uncomfortable outcome, given that Vave is this site's paid partner, and the reason this fact also appears on without a licence number.

Station two: the licensor

If the operator does not come across, the next step is the body that issued its licence. This is the reason a licence number has practical value: it points to an address where somebody other than the operator can look at the matter.

For four operators that is the Curaçao regulator: Bitcasino.io, Bitsler, Cloudbet and Stake, with the numbers OGL/2023/111/0069, OGL/2024/930/0387, OGL/2024/328/0599 and OGL/2024/1451/0918. For three operators it is the Anjouan Gaming Board: Empire.io with ALSI-132405042-FI3, CoinCasino with ALSI-142311005-FI2 and Rakebit with ALSI-202602030-FI2.

At Primedice there is a number — 8048/JAZ, under the designation Government of Curaçao — but we found it only on the operator's own terms page and not in a register of an issuing body. At Vave and BetPlays our data holds no jurisdiction and no number. For those two this station therefore simply does not exist: there is no designated body to go to.

And with the three Anjouan operators there is an extra fold in it, which is worked out on the Anjouan licence: the standard terms of that licence name the Netherlands as a prohibited jurisdiction, while those operators' own country lists do not exclude the Netherlands. A complaint you file with that body therefore begins with a question about your own position.

Station three: the Kansspelautoriteit, and what it is and is not

Here a misunderstanding has to go. The Kansspelautoriteit is a regulator, not a debt collection agency and not a disputes committee for individual money claims. It enforces the Dutch rules and acts against operators active on the Dutch market without a licence.

What that means: a report to the Kansspelautoriteit is useful as a signal and can contribute to action against an operator. What it is not, is a route to getting your own balance back. Anyone who expects that and does not get it takes from the experience the conclusion that "nothing can be done about it", when in fact they were standing at the wrong counter.

With an operator that does hold a Dutch licence it lies differently, and that is exactly the difference. There, a mandatory complaints procedure is attached to the licence, and there the regulator has means that work in the Netherlands. What else is in that package is set out under what a Dutch licence requires.

Station four: the court, in theory

That leaves going to court. In theory that is the keystone of every dispute; in practice, in cases of this kind, it usually founders on three things at once: which court has jurisdiction, which law applies, and whether a judgment can afterwards be enforced against a company outside Europe. Those three questions are worked out under the applicable law.

This site has collected no case law and makes no prediction about how such a case ends. What we can say is that the costs and the lead time of this route rarely bear any relation to the amounts that are usual in this subject, and that this is the reason stations one and two are in practice the only stations that count.

The most useful way to use this page is to read it before anything goes wrong, and then from the bottom up.

Anyone who asks himself whether he feels comfortable with station four knows straight away how much weight station two has to carry. And anyone who sees that station two is missing entirely at a particular operator — no licensor, no number, no body — knows that everything has to come down to station one: the operator itself, with its own terms, of its own free will. That can go well. It is simply a different arrangement from the one most people think they are making.

Algemene voorwaarden van CoinCasino, artikel 1 tot en met 3
Artikel 3 legt de plichten bij de speler: 3.1 laat CoinCasino op elk moment een leeftijdsbewijs opvragen, 3.3 eist dat je woont in een rechtsgebied waar gokken is toegestaan, en 3.4 verbiedt VPN, proxy en elk middel dat je werkelijke locatie maskeert.
Exploitatiecertificaat van de Curaçao Gaming Authority voor cloudbet.com
Exploitant volgens het certificaat: Halcyon Super Holdings B.V., nummer 148526, vergunning OGL/2024/328/0599, verleend op 23-05-2025, status „Active".