Dutch KSA Rejects Polymarket Appeal and Reaffirms Gambling Classification

The Netherlands’ gambling regulator, the Kansspelautoriteit (KSA), has formally rejected Polymarket’s appeal and doubled down on its classification of the platform as an unlicensed gambling operator. The ruling, published June 23, 2025, puts Adventure One QSS Inc., the corporate entity behind Polymarket, on notice that enforcement action will follow if the platform continues serving Dutch consumers without a license. For the broader crypto industry, the decision signals that regulators will not accept blockchain architecture as a legal shield against gambling law.

By Ryan Mitchell | July 10, 2025

KSA Publishes June 23 Ruling Against Adventure One QSS Inc.

What the Dutch Regulator Actually Decided

The Kansspelautoriteit, which oversees all gambling licensing and enforcement in the Netherlands, published its appeal decision on June 23, 2025, confirming that Polymarket’s operations fall squarely within the definition of gambling under Dutch law. The KSA had previously issued a preliminary classification, and Adventure One QSS Inc., the registered operating company for Polymarket, formally challenged that finding. The regulator reviewed the challenge and rejected it in full [1].

The KSA’s position is grounded in the Dutch Wet op de kansspelen, the national Betting and Gaming Act, which defines gambling as any game in which participants stake money on an uncertain outcome. Under that definition, Polymarket’s prediction contracts, where users deposit funds and receive payouts based on whether a real-world event occurs, meet every element of the statutory test. The regulator made clear that the mechanism of settlement, whether cash, cryptocurrency, or any other asset, does not change the legal character of the activity.

The KSA’s enforcement toolkit is significant. Under Dutch gambling law, regulators can impose fines of up to €870,000 per violation, order Dutch internet service providers to block access to unlicensed platforms, and pursue further administrative penalties for continued non-compliance. The June 23 ruling confirmed that all of those options remain available if Polymarket does not bring its Dutch operations into compliance [1].

The Timeline: How the KSA-Polymarket Dispute Developed

Polymarket launched in 2020, founded by Shayne Coplan, and grew rapidly on the back of high-profile prediction markets covering U.S. elections, cryptocurrency prices, and geopolitical events. The platform operates on the Polygon blockchain and uses USDC as its settlement currency, a design Polymarket has consistently argued places it outside traditional gambling frameworks. By 2024, Polymarket was processing hundreds of millions of dollars in monthly trading volume, attracting attention from regulators across multiple jurisdictions.

The KSA opened its review of Polymarket’s Dutch operations as part of a broader push to assess crypto-native platforms that accept Dutch consumers. The regulator issued its initial classification, Polymarket’s operating entity filed its appeal, and the June 23, 2025, decision closed that appeal process. The sequence matters because it means Polymarket has now exhausted its first line of administrative recourse in the Netherlands. Any further challenge would require litigation in Dutch courts.

Polymarket is not the only platform the KSA has scrutinized. The regulator has a documented history of pursuing offshore and crypto-adjacent operators who target Dutch consumers without a local license, including issuing blocking orders against several major international sportsbooks in prior years.

Why Polymarket’s ‘Blockchain Protocol’ Defense Failed

The Marketing Language That Undermined the Appeal

Polymarket’s core legal argument was that its platform does not constitute gambling because it facilitates peer-to-peer trades on an open-source blockchain protocol. Adventure One QSS Inc. argued that prediction market contracts are more analogous to financial derivatives than to casino games, and that the platform should therefore be regulated as a financial product rather than a gambling service. It is a legally coherent argument, and one that has gained traction in some jurisdictions.

The KSA rejected it, and the reason is instructive: the regulator cited Polymarket’s own marketing materials as evidence against the appeal. Those materials used phrases like “betting on future events” and were specifically directed at Dutch consumers. When a platform’s own promotional copy describes the activity as betting, regulators have little difficulty concluding that the activity is, in fact, betting. The KSA’s use of Polymarket’s marketing language as evidence is a textbook example of how self-description can undermine a legal reclassification argument [1].

The ruling also addressed the cryptocurrency and blockchain dimension directly. The KSA stated that the use of cryptocurrency and blockchain technology does not exempt a platform from gambling regulations. This is consistent with the position taken by regulators in the United Kingdom, Malta, and several other European jurisdictions, all of which have confirmed that crypto-denominated wagering is subject to the same licensing requirements as fiat-denominated gambling.

The Financial Product Argument: Where It Works and Where It Doesn’t

The financial product framing has succeeded in at least one major jurisdiction. In the United States, Kalshi received approval from the Commodity Futures Trading Commission (CFTC) to operate as a regulated derivatives exchange, allowing it to offer event contracts on U.S. elections and other outcomes. That approval, granted after years of regulatory engagement, gave Kalshi a legal foundation that Polymarket has not replicated in most markets where it operates.

The distinction the KSA drew is partly about regulatory category and partly about consumer targeting. A platform that registers with a financial regulator, complies with derivatives trading rules, and markets itself as a financial instrument occupies a different legal position than one that uses gambling-adjacent language to attract retail users in a jurisdiction where it holds no license of any kind. Polymarket’s situation in the Netherlands reflects the latter scenario, and the KSA’s ruling reflects that reality.

Decentralized prediction market protocols like Augur and Manifold Markets have faced similar definitional questions in various jurisdictions, though neither has faced a formal enforcement ruling from the KSA. The Polymarket decision sets a precedent that Dutch regulators will apply the gambling classification broadly to any platform where users stake value on uncertain outcomes, regardless of the underlying technology stack.

How Regulators Classify Prediction Markets in 2025

The regulatory picture for prediction markets in 2025 is fragmented but trending toward stricter classification. Most European regulators apply their existing gambling frameworks to prediction market platforms, treating the staking of value on uncertain outcomes as gambling regardless of whether the platform calls itself a financial exchange. The KSA’s June 23 ruling fits squarely within that European consensus.

The United States represents the most significant exception. The CFTC’s approval of Kalshi as a designated contract market in 2023 created a pathway for prediction markets to operate legally as financial products, provided they register with the appropriate derivatives regulator and comply with CFTC rules. Polymarket has not pursued that pathway, and U.S. users are blocked from the platform. The contrast between Kalshi’s regulatory engagement and Polymarket’s approach illustrates two very different strategies for the same underlying product type.

Within the European Union, the absence of a harmonized framework for prediction markets means each member state applies its own gambling laws. The Netherlands, under the KSA, has now produced one of the clearest written rulings on the subject, which means the June 23 decision may be cited by regulators in other EU member states as persuasive authority when they assess similar platforms. A single national ruling can have outsized influence when it is well-reasoned and publicly published.

The broader crypto gambling compliance environment has tightened considerably since 2022. Regulators across Europe have moved to close loopholes that allowed crypto-denominated platforms to argue they fell outside gambling law. The KSA’s position that cryptocurrency and blockchain technology do not create a regulatory exemption is now the mainstream European view, not an outlier position [1].

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What the KSA Ruling Means for Crypto Poker and Bitcoin Gambling Platforms

The Polymarket ruling carries direct implications for any crypto-native platform that accepts users from regulated European markets. The KSA’s core holding, that blockchain settlement and peer-to-peer architecture do not exempt a platform from gambling law, applies with equal force to crypto poker rooms, bitcoin sportsbooks, and decentralized casino protocols that serve Dutch or broader EU consumers. If your platform takes value from users and pays out based on uncertain outcomes, European regulators will classify it as gambling, full stop.

For players using crypto poker platforms that operate under proper licensing, such as those reviewed at our crypto poker platform reviews, the KSA ruling is a reminder of why licensing jurisdiction matters when choosing where to play. A platform licensed by the Malta Gaming Authority or the UK Gambling Commission has gone through the regulatory process that Polymarket bypassed in the Netherlands. That licensing status is not just a legal formality; it is the difference between a platform that can operate openly and one that faces blocking orders and fines. Players comparing options like those covered in our CoinPoker vs ACR Poker breakdown benefit from understanding that both platforms operate within defined regulatory frameworks, which is precisely what the KSA demanded of Polymarket.

The ruling also signals that crypto poker operators who market their services using gambling-adjacent language, even casually in promotional materials, hand regulators a ready-made argument for classification. The lesson from Polymarket’s failed appeal is operational as much as legal: platform language, marketing copy, and user-facing descriptions all become evidence in a regulatory proceeding. Operators who want to maintain a financial-product framing need to ensure every consumer-facing communication is consistent with that framing, or they risk the same outcome Adventure One QSS Inc. received on June 23.

Key Takeaways

• The Dutch KSA published its appeal ruling on June 23, 2025, confirming Polymarket’s classification as an unlicensed gambling operator in the Netherlands.
• Adventure One QSS Inc., Polymarket’s operating entity, filed the appeal and lost; the platform has now exhausted its first administrative recourse in the Netherlands.
• The KSA cited Polymarket’s own marketing materials, which used the phrase “betting on future events,” as direct evidence supporting the gambling classification.
• Dutch gambling law allows the KSA to impose fines of up to €870,000 per violation and to order ISP-level blocking of non-compliant platforms.
• The KSA explicitly stated that cryptocurrency and blockchain technology do not exempt a platform from Dutch gambling regulations, aligning the Netherlands with the UK, Malta, and France on this point.
• Kalshi’s CFTC approval in the United States demonstrates that a financial-product classification for prediction markets is achievable, but requires proactive regulatory engagement that Polymarket has not pursued in Europe.
• The June 23 ruling may serve as persuasive authority for other EU member state regulators assessing prediction market platforms in 2025 and beyond.

Frequently Asked Questions

The Bottom Line

The KSA’s June 23, 2025, ruling against Adventure One QSS Inc. is more than a single enforcement decision against a single platform. It is a clear statement from one of Europe’s most active gambling regulators that the crypto-native architecture of a platform, its blockchain settlement, its peer-to-peer framing, its open-source protocol, does not override the fundamental question of whether users are staking value on uncertain outcomes. If they are, it is gambling. The technology is irrelevant to that classification.

For Polymarket, the immediate path forward involves either obtaining a Dutch gambling license, which would require meeting KSA standards for player protection, AML compliance, and responsible gambling, or geo-blocking Dutch users entirely. The platform’s marketing language, which the KSA used as evidence against it, will need to change regardless of which path Adventure One QSS Inc. chooses. The broader prediction market industry, including platforms like Augur, Manifold Markets, and any future entrants, now has a detailed, publicly available ruling to study before they decide how to approach European markets.

Regulators do not move slowly when they have already ruled once and been challenged. The KSA has made its position clear twice now. The next move belongs to Polymarket, and the clock is running.

Sources

1. GamblingNews.com – Dutch KSA reaffirms Polymarket gambling classification, rejects Adventure One QSS Inc. appeal, June 2025