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Dutch Supreme Court Limits Nullity Claims Against Unlicensed Online Gambling, July 2026

The Dutch Supreme Court issued a preliminary ruling on 3 July 2026 on online gambling contracts with operators lacking a Dutch licence. It held that breach of Article 1(1)(a) of the Gambling Act does not make those contracts null or voidable under Article 3:40 of the Civil Code, while leaving defect-of-consent and tort claims open.

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The Dutch Supreme Court issued a preliminary ruling on 3 July 2026 in two online gambling cases. Players sought repayment of gambling losses from Malta-based operators that lacked Dutch licences.

The ruling turns on Article 1(1)(a) of the Dutch Gambling Act and Article 3:40 of the Civil Code. The court held that the Gambling Act did not intend to impair contract validity where an operator breached the licensing prohibition.

Unlicensed online gambling operators gain a narrower defence to automatic restitution claims based only on statutory nullity. Players and claims vehicles must plead other grounds, including defects of consent, tort, unfair commercial practices, or mistake, where facts support them.

The court left those alternative claims open. It did not answer restitution consequences because it rejected nullity. It also applied the same approach where an operator says it only enables players to play against each other.

Licentium may advise operators, investors, payment providers, and affiliates on litigation exposure directly or through Dutch counsel. Work we undertake includes iGaming, licensing analysis, player-claim risk, consumer-law review, payment controls, and market-entry structuring.

Source: Hoge Raad, 3 July 2026, ECLI:NL:HR:2026:1159.

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