Paid Search Is Permitted in Finland. Your Keyword List Probably Isn't.

Paid Search Is Permitted in Finland. Your Keyword List Probably Isn't.

First in a series of six on marketing under the Finnish gambling licence. OnlyiGaming, Industry Voices. By Gloria Kesa, FinEst Verba.

Most Finnish entry plans I have read this year make the same structural mistake, and it is not a mistake about any single rule. It is a mistake about how the Act is built.

The Finnish Gambling Act (Rahapelilaki 10/2026) does not describe prohibited marketing and permit whatever is left over.

It names the channels a licensee may use, and everything not named is prohibited. Section 51 is a closed list.

That single design choice is why a plan carried over from Sweden, the Netherlands or Ontario does not adapt to Finland. It fails, channel by channel, for a different reason in each case.

This series works through those failures one at a time. It starts with paid search, because paid search is the one almost everybody believes they have already solved.

The reasoning goes: affiliates are out, so the acquisition budget moves to search, which is permitted. The first half is right. The second half is right in a way that will not survive contact with an actual campaign build.

Search engine advertising is a named permitted channel. It is also the narrowest permission in the entire marketing chapter, and most media plans I see would breach it in week one without anyone involved intending to.

Where the permission came from, which tells you how it was meant to be read

Paid search was not in the government bill. HE 16/2025 did not include it. The Administration Committee added it at the parliamentary stage, in HaVM 28/2025 vp. Nordic Law describes it as the main marketing improvement in the final Act compared with the bill.

That history matters because it explains the shape of the permission. The stated reason was channelling. Someone already searching for a licensed operator or one of its games should be able to find that operator rather than an offshore site. Search was treated as a pull channel, not a push channel. Generic demand was deliberately left outside.

Read the permission as a channelling tool and the boundaries stop looking arbitrary.

The test

Keywords must be directly related to the licensed operator, or to that operator's own games.

Medialiitto puts it as marketing that may be attached only to searches for the licensed gambling company, or to word searches immediately related to its gambling games. Borenius applies the same test.

"Its games" means games that licensee actually offers under its Finnish licence. Not the game type. Not the category.

What that leaves in, and what it takes out

The following is my reading rather than a published list, because no keyword guidance has been issued by the Police Board or the Supervisory Agency yet. The line will be drawn in enforcement and in the marketing plan filed with each licence application.

Likely inside: the licence holder's trading and brand names as they appear in the licence file, the distinctive names of that operator's own games, and close variants around those terms on exact or phrase match.

Likely outside, and this is the part that breaks budgets:

• Category terms. Nettikasino, kasino, vedonlyönti, online casino, paras kasino. This is the entire generic head of the market.

• Competitor brand names. Conquesting is standard practice in most markets and has no route in under a test written around the operator's own identity.

• The bonus and offer lexicon. Casino bonus, ilmaiskierrokset, tervetuliaisbonus. Welcome offers are prohibited as acquisition marketing anyway, so bidding on the queries that look for them fails twice over.

• Generic game types used as category words. Slots, roulette, blackjack, kolikkopeli. A named game the operator runs is a different thing from the game type.

The operational failure mode is broad match, not intent

Nobody will deliberately write "nettikasino" into a Finnish campaign. They will run brand campaigns on broad match, and Google will expand onto category and bonus queries on its own, because that is what broad match is for.

The keyword list that was compliant when it was built stops being compliant the moment the platform starts matching. That is the most likely way a licensed operator breaches this section, and it will happen inside a campaign that somebody signed off.

Four things follow, all of them build decisions rather than legal ones:

• Separate brand campaigns from everything else, containing brand terms and the operator's own game titles only. A category campaign that also contains the brand is not a brand campaign.

• Use exact and phrase match. Not broad, not as a default, not to gather data.

• Negative-keyword the entire category and bonus lexicon at account level, so no campaign can expand onto it.

• Send the traffic to the operator's own licensed site. Not a click-out, not a redirect, not an unlicensed .com.

Being on a permitted keyword does not make the ad permitted

The channel permission and the content rules are separate tests and both apply.

Ad copy still has to pass the content restrictions in section 52. No framing that presents gambling positively or as an ordinary part of everyday life, no suggestion that it improves social standing, no credit hook, no misrepresentation of the chances of winning. Most standard casino ad copy fails on the first of those before anyone reaches the second.

Section 55 then requires every marketing communication to carry the age limit and where to find play management tools and help for gambling problems. That includes a search ad. Put it in the template, not in a reviewer's checklist, because a production brief written from the content rules alone will ship ads without it.

The moderation standard sits on top of all of it. Marketing must remain moderate in extent, scope, visibility and frequency. A campaign built entirely from permitted keywords with permitted copy can still breach the Act by being too big or too repetitive. Volume is not a defence. Volume is the exposure.

Display, Performance Max, YouTube and Discovery are not this

The permission is for search engine advertising on a keyword test. The rest of the Google stack is not keyword advertising and does not sit inside this limb. If a Performance Max campaign is in the Finnish plan because it has search in its inventory, that is a different conversation with a different answer.

The part almost nobody has priced: you cannot run this yet

First licences take effect on 1 July 2027. Until that date, Veikkaus holds the monopoly and marketing gambling to Finland by any other operator remains prohibited.

Geo-targeting Finland with a brand search campaign before that date is unlicensed marketing, even on terms that will be perfectly lawful afterwards. Enforcement has been weak, which is not the same as permission.

For an applicant it is sharper. Licence applications are assessed against fitness and propriety, and the disqualifying factors include penalties for unlicensed gambling operations. An applicant running visible Finnish paid search in 2026 is conducting prohibited marketing while its character file sits open with the authority deciding its application.

What to do with ten months left

Build the keyword list now and do not switch it on. Brand terms and own game titles, exact and phrase, with the category and bonus negatives already in place. Write the ad templates now, with the section 55 disclosures built into the artwork rather than added later. Then keep a dated written record of why each keyword was judged to be directly related to the operator or its games, because that judgement gets assessed after publication, not before.

Search is one of the few acquisition channels the Finnish Act leaves standing. The permission is narrow, and a plan that treats it as a like-for-like replacement for affiliate volume will find that out expensively.

What the rest of this series covers

Paid search is the channel people think they have solved. The next five deal with the ones they know are a problem and have not yet costed.

Next: the affiliate exclusion, which has no clause. Affiliate activity is not banned by name anywhere in the Act. A named affiliate provision was dropped during drafting, and the exclusion now runs entirely through the closed list in section 51. For a media plan the outcome is identical. For an argument with counsel who has read the Act and cannot find the ban, the mechanism is the whole conversation.

Then the bonus split, where acquisition offers are prohibited and retention offers are conditional on terms almost nobody has pinned down. The two-year direct marketing rule, which is a database query most CRM systems cannot currently run. The moderation standard, and why rising media prices meeting a cap on volume inverts the usual relationship between budget and share of voice. And the content restrictions with the section 55 disclosures, which rule out the register most casino copy is written in before it reaches a channel at all.

The full reading of Chapter 4, section by section, with every common marketing activity classified as permitted, prohibited or conditional, is published at finestverba.com/marketing-under-the-finnish-licence.

This is a practitioner's reading of the Act and its parliamentary materials. It is not legal advice and no compliance sign-off is offered. Operators making a licensing or spending decision should have Finnish gambling counsel confirm the position on their specific facts.

Gloria Kesa writes and translates regulated-market content for the Finnish and Estonian markets. Legal translation since 2010, terms of service and privacy policies for iGaming, crypto and trading platforms since 2017, native Finnish and Estonian.

Sources: Rahapelilaki (Gambling Act 10/2026), Chapter 4, sections 51, 52 and 55. HE 16/2025. Administration Committee report HaVM 28/2025 vp. Published analysis from Nordic Law, Medialiitto and Borenius.