Promoted feature: The virtues of service outsourcing

Armand Lecorché of IDEMIA outlines five reasons why it may be best for operators entering the Netherlands to rely on an external provider instead of developing a data-based control system in-house

The revision of the Dutch Gambling Act, passed by the Dutch Senate on February 2019, stipulates the use of a data-based control system known as a Controle Data Bank, or ‘CDB’. The purpose of this system is to ensure a secure exchange of regulatory data between licensed operators and Dutch regulators.

Following the publication of the CDB specifications[1] by the Kansspelautoriteit (the Netherlands Gambling Authority) in December 2020, gaming operators can either develop a CDB in-house, or rely on an off-the-shelf CDB service. Here are five important points that gaming operator should consider before making their decision:

The timing is short: the licence application process opened on 1 March, just four months after the publication of the CDB specifications. It typically takes several months to develop and validate a vault software in-house and the vault should be up and running when applying for the licence – an in-house vault development may delay the licence granting date.

The CDB specifications are comprehensive and specific: the CDB specifications are very comprehensive, covering functional requirements with a strong focus on data integrity, eligibility, continuous validation and monitoring, strong privacy requirements in line with General Data Protection Regulations (GDPR) and EDPB[2] guidelines, implementation requirements involving cryptography and Public Key Infrastructure (PKI), operational requirements including a final repository in the Netherlands, and testing requirements under KSA[3] supervision to highlight a few of them. The overall extent of safe implementation, testing and operational efforts should not be underestimated.

The data model may still be updated: data intended for the KSA must be strictly stored according to the XSD (XML Schema Definition) file structure provided by the KSA – but this XSD may still be modified between now and 1 September 2021, when the Netherlands market opens – software adaptation and additional testing could be required in the coming months.

The potential of the Netherlands market is still unknown: between the in-house software development investments, front-end testing with KSA, the initial and subsequent conformity assessment and the final repository in the Netherlands, gambling operators are looking at significant set-up and operational costs. Since these costs may be hard to recover, a pay-as-you-go offer might be more appropriate.

Time to market is essential: the competition is strong – according to the KSA, 180 operators have applied for a licence but only 90 licences will be granted. It will be key for gambling operators to be ready as soon as the market opens.

Online gaming operators that rely on an off-the-shelf traceability compliance service will benefit from a compliant solution from day one – without the pain of developing a CDB in a hurry, and without the hassle of needing to continue adapting it should the regulations evolve. In addition, an off-the-shelf solution will mean operators can avoid a significant upfront investment for an unfamiliar market as development costs will be shared between multiple operators.

IDEMIA is ready to provide a turnkey online gaming safe solution for the Netherlands, based on its compliance-as-a-service offer. This offer is already live in nine jurisdictions worldwide, is integrated with key gaming platform providers and has been adopted by 90+ online operators including nine of the top 10 Power 50 operators[4].

For more information, contact

Armand Lecorché is the director for online gaming solutions sales within IDEMIA’s Digital Business Unit. He heads worldwide sales for vault compliance services as well as digital identity services for gaming operators. Lecorché has a rich technical background, which he has built over a 20-year career in the software industry. His track record shows major achievements in various missions from business line management and business development to solutions marketing for subjects including OTA, NFC, mobile financial services, and subscription management.


[2] European Data Protection Board


[4] EGR‘s top 50 most influential internet gaming companies

Compliance | Data | IDEMIA | KSA | Netherlands | Regulation | Technology