Bulls Club

How to play Bulls Club

Kevin O’Neal, a DOCV board member, argued the scale of the investigation calls the GGL’s broader black market estimates into question. He cited the regulator’s 2025 activity report, which put the 2024 share at 23% (€547 million in gross gaming revenue), against Nielsen data suggesting a share of around 56%.

The trade body has long been critical over the discrepancy between channelisation estimates made by the regulator, and other independent reviewers.

The DOCV reinforced its calls for a unified federal licensing regime for online casino games and stronger enforcement mechanisms against illegal operators. 

How to play Bulls Club

The acceptance and authorisation process is restricted to paid media. Regarding organic content that sells, markets, depicts or promotes online gambling, Meta states, in the restricted products and services section, that it encourages safety, prevents potentially harmful activities and displays content only to those over 18 years of age.

The policies in question do not mention the practice of responsible gaming and do not detail other legal and regulatory obligations. They also do not specify the resources used to validate certifications, monitor licences and content, identify irregular practices and operators, or apply moderation measures. 

The absence of governance policies aligned with current regulations and Instagram’s algorithmic recommendations reveals not only an ecosystem that fuels gambling as an alternative to work, but above all, points to a systemic risk in which Meta is a major player. This risk can only be effectively addressed by expanding the obligations of digital platforms.

What is Bulls Club?

According to Nederlandse Loterij, illegal operators currently control approximately half of the Dutch online gambling market and account for roughly 95% of online gambling advertisements, frequently masquerading as licensed providers. 

The Loterij suggested around 200,000 Dutch citizens already engage with unauthorised platforms.

Earlier this summer, the Dutch Online Gaming Providers (VNLOK) trade body initiated legal action against Meta and lodged a formal complaint with the European Commission, accusing the social media giant of failing to prevent the widespread display of illegal online gambling advertisements targeting Dutch users on Facebook and Instagram.