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He emphasised the new system would make burdens less demanding than before, but the new ‘exit plan’ requirement and sharper duty‑of‑care definitions do bring some added complexity.

The KSA said that applicants were previously required to detail corrective actions taken to address previous breaches and outline measures to prevent future violations.

All submissions must also now include an exit plan – a new obligation that applies across the board. This requirement, intended to ensure orderly market withdrawal, marked a move toward embedding long-term risk management into the licensing process.

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“What I do think is that deciding together, not only as operators, but together with politicians and stakeholders, that a legal market is very important to get that done. We’re not there yet, and that’s what we’re saying.

“An unregulated market doesn’t become a safe market. People will always gamble, so we have to make sure that we have a strong legal market. And so you also need to give us some room to exist. And of course, we need to be regulated. A regulated market is always better than an illegal market.”

She mentions an ongoing lawsuit against Meta, which will be expected to be very challenging. The VNLOK-filed litigation is seeking to take action against the illegal gambling ads allowed to filter through to consumers across Meta’s various platforms.

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Halloween is a natural peg for that approach. It gives operators a topical, franchise-branded title to feature in October promotions without asking players to learn a new system. The friendly Count Dracula fisherman and trick-or-treat trimmings supply the seasonal hook while the underlying fish-collection loop does the heavy lifting.

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A fourth Halloween variant in one series also signals how far Pragmatic Play is willing to push iteration on a recognizable mechanical family. Familiarity is the point. Each seasonal skin trades on established player recognition rather than introducing a new core experience.