The Dutch gambling regulator has fined EOD Code SRL €37,250,000 for offering casino games and sports betting to players in the Netherlands without a licence. The company sits behind Instantcasino, Skyhills and 10 other crypto-friendly sites. It is the largest fine the Kansspelautoriteit (Ksa) has ever set for illegal gambling. The Ksa’s own formula came to €292.6 million. Dutch law cut it by 87%.
We read the full fine decision, the penalty order from 2025, the collection decision that followed it and two bans from the Swedish regulator. Below is how the number was built, what the inspectors saw on the sites, which terms raised the fine, who the companies are and what a player on one of these sites should do now.
- Fined company: EOD Code SRL, registered in San José, Costa Rica, corporate number 3-101-910497.
- Amount: €37,250,000 for offering games of chance without a licence, a breach of article 1(1)(a) of the Dutch Betting and Gaming Act.
- Sites: instantcasino.com, skyhills.com, slotmonster.com, betiro.com, betblast.com, fastslots.com, goldenpanda.com, sambaslots.com, winningz.com, incognitocasino.com, foxygold.com and luckypays.io.
- Dates: signed on 6 October 2026, sent on 7 October, made public on 22 October.
- How it was set: 270% of an estimated €108.4 million in Dutch gross gaming revenue for 2025, capped at 10% of estimated worldwide revenue.
- Earlier sanction: a 2025 penalty order of €280,000 a week. All €840,000 was forfeited and not paid.
- Next step: EOD Code can object within six weeks of 7 October. An objection does not suspend the fine.
Alex Jovanovic: “The headline number is €37 million. The number I would remember is €840,000. That is what this company already owed the Dutch regulator, and it never paid. A record fine is a record on paper. Collecting it is a separate problem.”
What the Dutch regulator decided
The fine decision is 17 pages long and signed in The Hague by Ksa chair Michel Groothuizen. The Ksa says EOD Code gave people in the Netherlands the chance to play games of chance without a licence. On instantcasino.com that meant online casino games and sports betting.
The case began with one site. Ksa inspectors first opened instantcasino.com from the Netherlands on 19 November 2024. In April 2026 they found 11 more sites that, according to the Ksa, the same company runs. The announcement of 22 October calls it “the highest fine the Ksa has imposed for illegal supply so far” (our translation).
The regulator did not announce the fine on X. Its account @Ksa_Nederland stopped posting on 6 January 2025. Its last post sends readers to Facebook, Instagram and LinkedIn.
“From 2025 the Kansspelautoriteit no longer uses X. Follow us on Facebook, Instagram or LinkedIn and stay up to date with our work.”
Ksa, last post on X, 6 January 2025 (our translation)
EOD Code did not take part. It did not answer a request for its financial data on 26 May 2026. It did not reply when the Ksa invited its view on the planned fine on 10 September. It had not answered earlier letters in 2025 either.
How €292.6 million became €37.25 million
With no figures from the company, the Ksa estimated its revenue itself. It used a search-volume method it published in February 2025. The method starts from how often people in the Netherlands search for a site and turns that into an estimate of gross gaming revenue, the money players lost.
| Step | Figure |
|---|---|
| Estimated Dutch gross gaming revenue of the 12 sites, 2025 | €108,374,000 |
| Basic fine under the 2026 fining policy | 100% of that revenue |
| Aggravating factors | +170 percentage points |
| Fine before the cap | 270%, rounded down to €292,600,000 |
| Legal cap | 10% of turnover in the previous year, read as worldwide turnover |
| Estimated worldwide revenue, 2025 | €372,989,000 |
| Highest fine allowed | €37,298,900 |
| Fine imposed | €37,250,000 |
The Ksa reads the 10% cap as a share of worldwide turnover and points to a 2026 ruling of the Dutch Council of State (ECLI:NL:RVS:2026:2302). On the Ksa’s own estimates the Netherlands made up about 29% of EOD Code’s worldwide revenue. The cap removed 87% of the calculated amount. The fine that is left equals about a third of one year of estimated Dutch revenue. Those three percentages are our arithmetic on the Ksa figures.
The 170 extra points
| What the Ksa found | Points |
|---|---|
| No visible and adequate age verification | 50 |
| Prohibited bets on offer | 20 |
| Inactivity fees on player accounts | 10 |
| Autoplay or turbo play | 10 |
| No play limits, or limits filled in in advance | 10 |
| Minimum deposit amounts | 10 |
| Deposits in crypto and other anonymous methods | 10 |
| Unfair terms and conditions | 50 |
Crypto has its own line. The Ksa counts deposits in cryptocurrency and other anonymous payment methods as a reason to raise a fine, because in its words they make money laundering easier. It did the same in the Novatech case in March.
Alex Jovanovic: “Notice that the biggest single line, 50 points, is age checks. The second biggest is the small print. A regulator that reads the terms page line by line is a regulator that players should listen to.”
What the inspectors saw on the sites
The decision describes how instantcasino.com received a visitor from the Netherlands. The site opened from a Dutch IP address. An inspector created an account with Dutch address details. At sign-up the Dutch dialling code +31 was filled in automatically. The Netherlands was not on the list of restricted countries in the terms.
- A deposit in Bitcoin. The inspector paid in a small Bitcoin deposit, worth €20 according to the fine decision. Balances from crypto deposits were shown in euro.
- Real play. The 2025 order records a session on The Dog House at the lowest stake of €0.20 with autoplay set to 10 spins, and one on Majestic Fury Megaways Unleashed at €0.10.
- Dutch support. The site itself was in English. Questions asked in Dutch were answered in Dutch, and the payment instructions were partly in Dutch.
- Dutch advertising. A Dutch-language website advertised Instantcasino.
- A mirror. On 24 July 2026, a year after the order, the Ksa checked again through instantcasino17.com. Dutch players could still play.
On the other 11 sites the inspectors found the same pattern between November 2025 and June 2026. “The Netherlands” appeared in the country field by default, +31 was offered for the phone number, and the payment flow was fully or partly in Dutch. Several sites offered Dutch payment routes.
| Site | Checked from NL | Dutch payment options in the decision |
|---|---|---|
| instantcasino.com | 19 Nov 2024 to 8 Jul 2025, Sep 2025, Jul 2026 | Bitcoin deposit by the inspector |
| skyhills.com | 24 Nov 2025 | Rabobank |
| slotmonster.com | 21 May 2026 | Rabobank, ING, ABN AMRO |
| betiro.com | 21 May 2026 | iDEAL, Rabobank, ING, ABN AMRO |
| betblast.com | 21 May 2026 | iDEAL, ABN AMRO, ASN Bank |
| fastslots.com | 21 May 2026 | None named |
| goldenpanda.com | 21 May 2026 | iDEAL, Rabobank, ING, ABN AMRO |
| sambaslots.com | 21 May 2026 | iDEAL, Rabobank, ING, ABN AMRO |
| winningz.com | 21 May 2026 | iDEAL, Rabobank, ING, ABN AMRO |
| incognitocasino.com | 10 Jun 2026 | ING, Rabobank, ABN AMRO |
| foxygold.com | 10 Jun 2026 | ING, Rabobank, ABN AMRO |
| luckypays.io | 10 Jun 2026 | ING, Rabobank, ABN AMRO |
Skyhills also had help from Dutch influencers. The decision says they posted links to the site on Instagram, YouTube and Discord, and that TikTok videos used Dutch text with the Skyhills logo. The Ksa served penalty orders on four of them in 2025: LeftlanePapi in June, and Turcos, StiefunSpeelt and Buurtwachtt in September.
The terms that raised the fine by 50 points
The Ksa read the Instantcasino terms and called several clauses an unacceptable disadvantage for players. We opened the live terms on 23 October 2026 to see which of them are still there.
| Clause the Ksa flagged | What it means for you | Live terms, 23 October 2026 |
|---|---|---|
| Inactivity fee of €5 a month from the 13th month | An unused balance shrinks every month | Changed and stricter: after 180 days without a login an account is dormant, and up to 10% of the balance a month may be deducted until €5 or less is left |
| Withdrawal caps | A big win is paid out slowly | Still €4,000 a day, €10,000 a week, €20,000 a month |
| Fee to withdraw money never wagered | You are pushed to play before you can cash out | Not checked clause by clause |
| Player funds on insolvency | If the operator goes bust, your balance may not come back | Still in clause 6.5 |
| No liability for game faults | The operator disowns fairness problems caused by technical failures | Not checked clause by clause |
| Balance kept on permanent self-exclusion | Asking to be shut out for good costs you your money | Still in clause 14.2: “any funds remaining in your account will be forfeited” |
The live terms add two more lines worth knowing. Winnings from a bonus that needs no deposit are capped at €10. And money deposited from a restricted country “will be considered forfeit”. The Netherlands is still not on that list. Curaçao is, which is odd for a site whose name sits on a Curaçao licence.
Alex Jovanovic: “The self-exclusion clause is the one that stops me. A player who asks to be blocked for good is often a player in trouble. Taking their balance at that moment is the opposite of what responsible gambling means.”
Four companies, several licences, no Dutch licence
The Ksa fined one company. The paper trail around these sites names at least four. None of them holds a Dutch licence, and none of the licences below allows gambling in the Netherlands.
| Company | Where | Role in the records |
|---|---|---|
| EOD Code SRL | San José, Costa Rica, 3-101-910497 | Fined by the Ksa. Named as owner in the Instantcasino footer and terms when the Ksa checked. Banned in Sweden in May 2025 |
| Atlantis Interactive SRL | Not stated | Earlier owner name in the Instantcasino terms. According to Creditsafe data cited by the Ksa, it now trades as EOD Code |
| Igloo Ventures SRL | San José, Costa Rica, 3-102-880024 | Named by Sweden as operator of instantcasino.com and 22 other sites. Anjouan licence ALSI-142311005-FI2. Banned in Sweden in May 2025 |
| Axenora Strategic Services N.V. | Curaçao, company 164834 | Curaçao licence OGL/2024/1788/1030, status active. Register monitors list instantcasino.com and four other casinos under it |
The two regulators also split the sites differently. The Ksa attributes all 12 to EOD Code. The Swedish decision on Igloo Ventures puts 10 of the same 12 under Igloo, among them Instantcasino and Skyhills. The Swedish decision on EOD Code names slotmonster.com, coinpoker.com, incognitocasino.io and thehighroller.com. Both Swedish bans are dated 12 May 2025, the same day Sweden banned a third company, MIBS N.V.
Skyhills adds another name. In September 2026 the Dutch state lottery, Nederlandse Loterij, took legal steps against the site and named a Curaçao company, Skyhills N.V., as its operator. The lottery says the companies and people behind Skyhills sit in Costa Rica, North Macedonia and the United Kingdom. Skyhills is no longer reachable from the Netherlands, according to the lottery. Its CEO Arjan Blok said Dutch players “can gamble there completely unprotected, with all the risks that brings. That is unacceptable.” (our translation).
The site itself does not settle the question. On 23 October 2026 we opened instantcasino.com from outside the Netherlands. It sent us to a mirror, instantcasino-34.com. Neither the terms nor the footer named a company or a licence. The footer showed a copyright line for instantcasino.com and a support address. When the Ksa checked in 2024, the footer and clause 1.1 of the terms named EOD Code.
No owner or director of any of these companies is named in the documents we read. A chain of Costa Rica and Curaçao companies with numbered names is a common setup for offshore crypto casinos. Our post on the Curaçao regulator leak explains why a licence line in a footer tells you less than it seems.
The €840,000 that was never paid
This was not the first sanction. On 29 July 2025 the Ksa ordered EOD Code to stop offering games to Dutch players within four weeks. The penalty order set €280,000 for every week of breach, up to €840,000. The deadline passed on 26 August 2025. Checks on 5, 12 and 19 September found Instantcasino still open to the Netherlands, so the full €840,000 was forfeited.
The money did not come. The Ksa wrote on 16 October 2025 that it would collect, got no answer and issued a collection decision on 11 December 2025. EOD Code objected to neither the order nor the collection. Both are now final, the Ksa case page says.
The Ksa chair wrote about this problem a week before the record fine was made public. In a column of 14 October Michel Groothuizen says fines on illegal operators send a clear signal “but hardly have an effect when it comes to collection. Frustrating.” (our translation). For that reason the Ksa now works on making illegal sites harder to find and cutting off their payments. Together with Google it is building a white list of legal operators in the EU. He also writes that for every euro gambled with legal Dutch operators, another euro goes to the illegal market.
The case in dates
| Date | What happened |
|---|---|
| 19 November 2024 | First Ksa check of instantcasino.com from the Netherlands |
| December 2024 to March 2025 | Three rechecks, site still open |
| 10 April 2025 | Ksa announces it plans a penalty order. No reply |
| 12 May 2025 | Sweden bans EOD Code, Igloo Ventures and MIBS |
| 18 June 2025 | Penalty order on influencer LeftlanePapi over Skyhills content |
| 29 July 2025 | Penalty order on EOD Code: €280,000 a week, up to €840,000 |
| 26 August 2025 | Deadline to stop passes |
| September 2025 | Three checks, €840,000 forfeited. Orders on three more influencers |
| 11 December 2025 | Collection decision on the unpaid €840,000 |
| 10 March 2026 | Previous record: €24,846,000 for Novatech (Qbet, 55Bet) |
| 23 April 2026 | Ksa finds 11 more EOD Code sites |
| 26 May 2026 | Ksa asks for financial data. No reply |
| 24 July 2026 | Instantcasino still open through the mirror instantcasino17.com |
| September 2026 | Nederlandse Loterij acts against Skyhills. Ksa invites EOD Code to respond to the planned fine. No reply |
| 6 and 7 October 2026 | Fine decision signed and sent |
| 14 October 2026 | Ksa chair column on collection |
| 22 October 2026 | Fine made public |
| 18 November 2026 | Six weeks after sending, by our count: last day to object and to pay |
Earlier cases of the same kind
This is the second record in 2026. On 10 March the Ksa fined Novatech €24,846,000 for Qbet.com and 55Bet.com and Fortaprime SRL €1,795,000 for eight sites. Groothuizen said then that without the 10% cap the Novatech fine would have come to more than €100 million. Before that the record was close to €20 million, set against Gammix in 2024.
The method is the same each time. Estimate revenue from search data, add points for crypto, missing age checks and unfair terms, then hit the cap. As long as the cap is tied to worldwide revenue, the more an operator depends on Dutch players, the smaller the share of its Dutch revenue a fine can reach.
What happens next
EOD Code can file an objection within six weeks of the day the decision was sent, 7 October. The same six weeks apply to payment. After that, statutory interest runs. An objection does not stop the fine from being due. By our count the six weeks end on 18 November 2026. The Ksa has not said whether EOD Code has objected or paid anything.
The fine rests on an estimate, because the company refused to share its numbers. If EOD Code wants a lower amount, the way to get it is to open its books. Nothing in its record so far suggests it will.
If you play on one of these sites
- If you live in the Netherlands, stop depositing. These sites have no Dutch licence. Dutch player protection, the national self-exclusion register and the Dutch complaint routes do not apply to them.
- Withdraw what you can, in steps. The caps are €4,000 a day and €20,000 a month. Plan a large balance over several weeks.
- Log in at least every few months. After 180 days without a login, up to 10% of the balance a month can be deducted.
- Withdraw before you self-exclude. Under clause 14.2 a permanent self-exclusion forfeits the balance. Cash out first, then ask for the block.
- Keep proof. Screenshot your balance, save withdrawal IDs and transaction hashes, and keep support replies.
- Watch for mirrors. A copy of a site on a new domain, like instantcasino17.com, is a common way around blocks. A mirror has the same company behind it and the same terms.
Dutch players who want to keep playing can find the operators with a Dutch licence on the Ksa website. If gambling has started to cost more than you planned, our responsible gambling guide lists free help.
What is still open
- Who owns EOD Code. No owner or director is named in any decision we read.
- Who runs which site. The Ksa and the Swedish regulator name different operators for 10 of the 12 sites. Instantcasino itself named no company or licence on 23 October 2026.
- Whether anything is paid. Neither the €840,000 nor the €37.25 million is reported as paid.
- Whether EOD Code objects. The window closes around 18 November 2026.
- Whether the sites block the Netherlands now. The live Instantcasino terms still leave the Netherlands off the restricted list.
Alex’s verdict
The decision is careful work. Dated checks over almost two years, a test deposit, real spins at the lowest stake, a line-by-line read of the terms and a fine built from a published method. Anyone who wants to know how a regulator sees an offshore crypto casino can read it as a manual.
The weak point is the end of the chain. The company behind these sites never answered and never paid the smaller bill. For players the useful part is the list of terms the Ksa flagged. Check your own casino for the same clauses: a dormant fee, low withdrawal caps, a balance kept on self-exclusion. If you find them, that tells you how the house treats your money when things go wrong.
I will update this post when the Ksa reports an objection, a payment or a court case. Our review method shows how we check the terms and licence of every casino we list.
EOD Code had no say in this post. The facts come from the Ksa fine decision of 6 October 2026, the penalty order of 29 July 2025, the collection decision of 11 December 2025, the Ksa announcement and case page of 22 October 2026, the Ksa chair column of 14 October 2026 and the Swedish ban decisions of 12 May 2025. We read the live Instantcasino terms and footer on 23 October 2026, reached through the mirror instantcasino-34.com. The document images are cut from the published PDFs without edits, and no page with bank details is shown. Quotes from Dutch are our translation. We did not open an account or deposit on any of the sites. The cover is an illustration made for this article.
FAQ
Who is EOD Code SRL?
A company registered in San José, Costa Rica, with corporate number 3-101-910497. The Dutch regulator says it runs Instantcasino, Skyhills and 10 other gambling sites. Its earlier name in the Instantcasino terms was Atlantis Interactive SRL.
How big is the Dutch fine on EOD Code?
€37,250,000. It is the largest fine the Kansspelautoriteit has set for illegal gambling. The previous record was €24,846,000 for Novatech in March 2026.
Why was the fine not €292.6 million?
Dutch law caps a fine at 10% of turnover in the previous year. The Ksa estimated EOD Code’s worldwide revenue for 2025 at €372,989,000, so the fine could not exceed €37,298,900. It was rounded down to €37,250,000.
Which sites are covered by the fine?
instantcasino.com, skyhills.com, slotmonster.com, betiro.com, betblast.com, fastslots.com, goldenpanda.com, sambaslots.com, winningz.com, incognitocasino.com, foxygold.com and luckypays.io.
Is Instantcasino licensed?
Not in the Netherlands. instantcasino.com is listed under a Curaçao licence held by Axenora Strategic Services N.V., and Sweden named Igloo Ventures SRL, which holds an Anjouan licence, as its operator in 2025. Neither licence allows gambling in the Netherlands. On 23 October 2026 the site itself named no company and no licence.
Can EOD Code appeal?
Yes. It can object within six weeks of 7 October 2026, the day the decision was sent. An objection does not suspend the fine, which is due in the same six weeks.
Did EOD Code pay the earlier penalty?
No. The Ksa found that all €840,000 under the 2025 penalty order was forfeited and not paid, and issued a collection decision on 11 December 2025. EOD Code did not object, so that decision is final.
Why does crypto make the fine higher?
The Ksa fining policy adds 10 percentage points when a site takes deposits in cryptocurrency or other anonymous methods. The Ksa says such payments make money laundering easier.
I have a balance on Instantcasino. What should I do?
Withdraw it in steps within the €4,000 daily cap, keep proof of every request, and log in at least every few months to avoid dormant fees. If you plan to self-exclude, withdraw first, because a permanent self-exclusion forfeits the balance under the terms.
Gambling is for adults only and can become addictive. Play only with money you can afford to lose, and read our responsible gambling guide if it stops being fun.
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Alex writes the house files on Crypto Casino Reviews. He plays the desks he scores and checks the offer, the cashier, and the licence before the long read.
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