The Affiliate Ban Nobody Wrote - Marketing Under Finnish Gambling Licence

An affiliate team opens the Finnish Gambling Act (Rahapelilaki 10/2026), searches for "affiliate", finds nothing, and reports that the ban does not exist.

The search worked. The conclusion is wrong.

I have seen founders spend six figures on legal opinions to justify a technicality, only to get hit with an enforcement decision because they misread the regulatory climate. Finding loopholes works until the regulator updates enforcement guidelines and cuts off your cash flow. Amateurs read a statute looking for what is allowed. They miss the structural context, the legislative intent, and the enforcement authority's appetite for penalties.

This is the second article in my series on marketing under the Finnish gambling licence. The first covered paid search. Paid search is a named permitted channel with severe keyword restrictions. Affiliate marketing does not have keyword restrictions. It lacks restrictions because it isn't permitted at all.

From 1 July 2027 affiliate placement is not a lawful channel for a licensed operator, though no section names it. Section 51 lists the permitted channels and prohibits the rest: the operator's own website and social accounts (non-interactive only), television and radio, sports and public events, print and equivalent digital publications, points of sale for the games sold there, and search ads on keywords directly related to the operator or its games. Brand-level outdoor and consented direct marketing sit in separate subsections.

The list, in full

Section references are to the Rahapelilaki. Translations are mine, from the Finnish text on Finlex.

Section 51, subsection 3:

Gambling games, and the licence holders that run them, may be marketed:

1. on the licence holder's own websites and own social media accounts, in such a way that the marketing is not interactive with the consumer;

2. in television and radio activity under the Act on Electronic Communications Services (917/2014);

3. at sports events and other public events;

4. in print media and in electronic publications corresponding to print media;

5. at points of sale, for the gambling games available at that point of sale;

6. in online search engines, when the search words used are directly related to the licence holder or to a gambling game it runs.

The statute has six points. Summaries that count seven split point 1 in two. The non-interactive condition attaches to all of point 1, websites included.

Subsection 4 permits outdoor marketing of the licence holder itself, away from schools, early childhood education, pharmacies, healthcare units and substance abuse units. Subsection 5 confines marketing of physical slot machines and casino games to the halls and casinos where they are placed. Subsection 6 refers direct marketing to section 54.

Then subsection 7, which does all the work: "Marketing of gambling games other than that referred to in subsections 1 to 6 is prohibited."

It names nothing. It does not need to.

The clause that was written, and removed

The government bill, HE 16/2025, had one: a proposed point 14 for the list of prohibited methods in section 52, a ban on using an identifier that tracks a consumer's web traffic while giving information that directs them, directly or indirectly, to a gambling site. The bill's rationale calls it the affiliate marketing ban.

The Administration Committee deleted it (HaVM 28/2025 vp) because, read literally, it could also catch other targeted digital marketing that uses tracking identifiers. Then the sentence to keep on file: the prohibition of affiliate marketing follows from section 51(3), which sets out the permitted channels.

The missing clause is not a loophole. Parliament said where the ban is at the moment it removed the clause.

Why there is nothing to negotiate toward

In most tightening markets the affiliate conversation is about form: lower CPA, hybrid deals, compliance addenda, approved copy.

Finland regulates where the marketing appears. A comparison site is not on the list at CPA, at revenue share or at a flat fee, with or without a compliance addendum.

The only surviving route is for the property itself to be a listed channel, which in practice means point 4, a publication corresponding to print media. This is reasoning, not a sourced rule, but it follows directly: what an affiliate business could sell into Finland is advertising inventory, priced and bought as media. That is a different product sold to a different buyer. It is not an affiliate deal with a new name.

Point 4 is also narrower than it sounds.

Influencers: a different failure route

Influencer, streamer and creator partnerships fail on the two conditions inside point 1.

The first is ownership. Point 1 covers the licence holder's own accounts, and a creator's channel belongs to the creator, whatever the contract says.

The second is interaction. The bill's rationale rules out two-way conversation and reacting to comments, emojis included. Reactions are tolerated only because the platforms build them in. A live stream with chat is interactive by design.

The Ministry of the Interior's reform Q&A is direct: commercial collaboration with social media influencers on the influencers' own accounts is not possible.

Sponsorship under section 56 is separate: the Ministry confirms that a sponsored individual may show the sponsor's logo on their own channels. Sponsorship may not bring out the licence holder's games. A logo on a jersey is sponsorship. A streamer playing the sponsor's slots is game marketing in an unlisted channel. Where a "sponsored creator" deal falls between those two is a contract-by-contract question for counsel.

Guest posts and sponsored articles: the conditional band

One camp treats every paid article as banned. The other treats anything labelled "sponsored" as fine. Both are wrong.

Point 4 can carry a paid placement. Two conditions apply, and the second is not in the Gambling Act at all.

The first is the publication. "Corresponding to print media" does not mean any website that publishes articles. The bill's rationale describes print media as, in particular, commercial newspapers and periodicals that sell advertising space, together with their electronic channels.

I would say 99% of affiliate properties are not built that way. The Administration Committee also said search advertising is not comparable to such a publication, and declined to extend permitted marketing to all digital channels.

Guidance has not yet settled how far the term reaches beyond established news and magazine titles.

The second is identifiability. The Consumer Protection Act (38/1978), chapter 2, section 4, requires that the commercial purpose of marketing, and on whose behalf it is done, be clearly apparent.

Put together, and this is my reasoning rather than a sourced rule: an operator's advertisement in a qualifying digital publication, clearly identifiable as advertising for that operator, is marketing in a listed channel. The same text bought as editorial, without that identification, is not advertising in the publication in any sense the list protects. It is marketing through an unlisted channel, and it fails the Consumer Protection Act on top.

What is assessed is the placement, not the link. Parliament deleted the clause aimed at tracked links pointing to gambling sites. Also reasoning: a tracked link is not what makes a placement unlawful, and removing the link does not rescue a placement in an unlisted channel.

Whether a given guest post placement qualifies is a question for counsel on the specific facts: the publication, the labelling, and the copy, which must still pass sections 52, 53 and 55.

What to do in the nine months left

Until 30 June 2027 Veikkaus holds the monopoly, and on the Ministry's own statement marketing other operators' gambling in Finland is not permitted. For affiliate traffic, 1 July 2027 changes the authority. The answer stays the same.

1.       Inventory. Every Finnish-language or Finland-targeted page, review, banner, bonus listing and tracked link, grouped by operator partner. Most networks cannot produce this in a day.

2.       Expect partners to ask for it. Under section 10(2)(8), an applicant is not fit for a licence if, within the two years before assessment and after 1 September 2024, it received a prohibition decision or penalty for gambling operations or marketing contrary to the Lotteries Act. Whether affiliate pages would be attributed to the operator is the authority's call. My reasoning: an applicant whose brand sits on your Finnish pages will want them gone sooner than you do.

3.       Agree retirement dates in writing, before 1 July 2027, item by item.

4.       Raise the revenue share tail now. Whether trailing commission paid after 1 July 2027 on players referred earlier is itself treated as marketing is not addressed in any source I have reviewed. Put it to the operator's counsel this year.

5.       Check what qualifies. If you own a real publication, the product is identifiable advertising sold to licensees.

6.       Keep a dated record of what was removed and when.

Next in this series

The bonus split: acquisition offers are prohibited, retention offers are conditional, and the condition rests on a term nobody has pinned down.

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. Anyone making a commercial or licensing decision should have Finnish gambling counsel confirm the position on their specific facts.

The full section-by-section reading of Chapter 4, with common marketing activities classified, is at https://finestverba.com/marketing-under-the-finnish-licence/.

Sources: Rahapelilaki (Gambling Act 10/2026), sections 10, 51, 52, 53, 55 and 56 (Finlex). HE 16/2025 vp. Administration Committee report HaVM 28/2025 vp. Consumer Protection Act (38/1978), chapter 2, section 4. Ministry of the Interior, questions and answers on the gambling system reform. Nordic Law, Marketing in Finland's Reformed Gambling System, and Recent Developments in the Finnish Gambling Reform. Borenius, Finland's Gambling Act Reform: A Practical Guide to the New Licensing Regime, 28 May 2026.