The Netherlands Followed Belgium. The Kansspelautoriteit's 2018 Finding and What It Required.

The Dutch gambling regulator ran its own loot-box investigation in 2018 and reached similar conclusions to Belgium — but the enforcement path diverged sharply.

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Two Regulators, One Season, Different Teeth

The Kansspelautoriteit (KSA), the Netherlands' gambling authority, published its loot-box findings in April 2018 — within days of the Belgian Gaming Commission's ruling that certain loot boxes constituted gambling under Belgian law. The KSA had opened its investigation in 2017, examining ten unnamed games; it concluded that four of them offered loot boxes that crossed into illegal gambling under the Dutch Wet op de kansspelen (Games of Chance Act). The key test was transferability: boxes whose contents could be traded or sold for real-world value were treated as prizes under the Act, making the mechanic a kansspel — a game of chance — requiring a licence the publishers did not hold.

The Belgian commission had named its games. The KSA did not, at least not initially, which blunted immediate public accountability. The regulator did, however, issue compliance orders to the publishers of the four non-compliant titles, demanding that the offending mechanics be disabled for Dutch players or that the publisher obtain the appropriate licence — effectively an impossible ask for a cosmetic drop system. Electronic Arts and Valve Corporation were among the publishers later identified through enforcement correspondence and press reporting, though the KSA's own published findings ↗ set out the legal reasoning without naming them in the original report.

EA contested the KSA's order rather than change FIFA's Ultimate Team mode for Dutch players, and the Dutch Council of State later overturned the fine. Valve disabled trading and Steam Community Market transfers of CS:GO and Dota 2 items for Dutch players, and later blocked CS:GO case opening in both the Netherlands and Belgium. Neither action was accompanied by an admission that the mechanics had constituted gambling. The KSA's available fine for non-compliance under the 2018 framework reached €830,000 per violation — a credible deterrent for the Dutch market specifically.

Where Belgium's ruling fed directly into a parliamentary call for EU-level coordination, the KSA framed its position as an interpretation of existing law rather than a demand for new legislation. That distinction mattered: it let publishers treat compliance as a local carve-out rather than a precedent requiring global product changes.