The Two Bonus Rules Finnish Operators Keep Merging

The Finnish launch plan reaches the board. Someone asks the commercial director what the welcome offer is. There is none, and the room assumes the CRM team has been too careful.

Are bonuses allowed under the Finnish gambling licence? As acquisition, no. As retention, on conditions. The Gambling Act (Rahapelilaki 10/2026) prohibits free play, discounted play, combined offers and any play money other than the bonus play money in section 26. Section 26 permits moderate bonus play money during an established customer relationship, on equal terms among customers, and not based on time spent gambling or proportional to money spent on gambling. The wagering requirement may be at most five times the bonus. A welcome offer cannot meet those conditions. The government bill states the split: no bonus play money in customer acquisition, but it may be offered to maintain the customer relationship (HE 16/2025, p. 164).

The CRM team found two rules where launch decks, in my experience, often show one. The first decides what an operator may give a customer. The second decides what it may advertise. Both apply from 1 July 2027, when the Act mainly comes into force; parts have applied since 1 March 2026.

The acquisition prohibition, and what it removes

Section references are to the Rahapelilaki. Translations from the Finnish are mine.

The bonus rules sit in chapter 3, on the operation of gambling. Section 25, subsection 3:

The exclusive licence holder and the gambling licence holder may not offer gambling games free of charge, at a reduced price or with combined offers, or offer play money other than in the form of the customer bonus play money referred to in section 26.

Section 52 repeats this for marketing: point 8 with the same section 26 exception, and point 13 for other goods offered free or at a reduced price, other than as section 26 allows.

The bill gives examples of what falls outside (HE p. 301): bonuses for non-customers, loyalty programmes, and similar benefits that encourage more play or reward the amount of play or deposit size.

That removes the welcome package, the welcome deposit match, free spins on registration, the risk-free first bet and the VIP tiers. The bill itself calls bonus spins and bonus money a very common form of marketing, especially in acquiring new customers (HE p. 326).

The retention permission, as a checklist

Section 26, subsections 2 to 5, can be read as eight conditions. A CRM lead needs all eight.

1.       Established customer relationship. Bonus play money is permitted only during one (26(2)).

2.       Moderate in amount (26(2)). The Act gives no figure.

3.       Equal terms among customers (26(2)). The bill's rationale (HE p. 301): bonus play money is to be offered to all customers on the same terms. My reasoning: a reload for a high-value segment alone fails here.

4.       Not tied to time or spend. Receiving bonus play money may not be based on time spent gambling, or be proportional to the money spent on gambling (26(2)). My reading: a reload deposit match is proportional to money by design, and the bill's rationale for section 25(3) lists rewards for deposit size among the prohibited benefits (HE p. 301).

5.       Duty of care first. The operator must first ensure it does not endanger its section 34 duty to protect players from excessive gambling (26(3)).

6.       Transparent terms, available to customers and easy to understand (26(4)).

7.       No direct conversion to cash (26(5)).

8.       Wagering no higher than five times (26(5)):

The exclusive licence holder and the gambling licence holder may set a wagering requirement of at most five times for bonus play money.

The cap attaches to the bonus play money; the statute does not mention deposits.

The established customer problem

Every point above depends on point 1, which is undefined. The Finnish is "vakiintuneen asiakassuhteen aikana", during an established customer relationship. Neither the Act, nor the bill's rationale for section 26, nor the Administration Committee report (HaVM 28/2025 vp, where vp marks the parliamentary session) defines the term. The bill's only glosses I have found are "existing customers", in its rationale for section 25(3) (HE p. 301), and "to maintain the customer relationship" (HE p. 164). Neither sets a threshold. The Ministry of the Interior's Q&A drops the word: "during the customer relationship".

Both observations are reasoning, not sourced rules. First, if "established" meant registered, the word would add nothing, because every recipient of bonus play money already has an account. The bill's gloss "existing customers" points to a lower threshold, which limits this observation. Second, subsection 1, on non-gambling benefits, says only "customer relationship", so the Act separates the two terms within one section.

What makes a relationship established is not stated in any source I have reviewed: a period of time, a number of sessions, a first deposit, or something else. This is unsettled.

A day-two reload assumes an answer to that question. The operator's counsel has to settle what counts as established for each product, in writing, before anyone designs the reload.

The advertised bonus trap

Section 26 governs giving a bonus to a customer. Chapter 4 governs marketing, which the Act defines as advertising, indirect advertising and other sales promotion (section 4, point 7). On that definition, a bonus that is announced is being marketed, so in my reading both chapters apply.

Take a ten euro bonus credit for existing players that meets all eight points. In my view, the practical route is a direct message to the customer, and section 54 sets the screens: express consent, no block on all gambling, play of this operator's games within the last two years, and no telephone. A customer with a game-specific block may receive marketing only for games they have not blocked. With the section 55 information included, that message is retention. The two-year window in section 54(3) is the only explicit time period for direct-marketing eligibility. No provision sets a numeric minimum period as a customer, though "established" in section 26(2) may imply some duration.

Put the same offer in a television spot. Television is a listed channel (51(3)(2)), and section 52(8) excepts section 26 bonus play money from its ban. No provision expressly prohibits this spot, though counsel would weigh moderation (51(2)) and the ban on inciting gambling (52(1)). My reasoning, not a stated rule, rests on an assumption: that most of a television audience are not established customers of the advertiser. On that assumption, the spot tells them that joining leads to ten euros. That is an acquisition incentive, which, on the bill's account (HE p. 164), section 25(3) prohibits and section 26 does not cover. On this reading: same offer, two legal characters, decided by where it appears.

The bill's rationale for point 8 keeps the section 26 exception inside the marketing ban, but explains the concern (HE p. 326): offers are meant to draw consumers to gambling, and unrestricted marketing of bonus spins and bonus money can make playing with them look risk-free. I have found no source that addresses an advertised retention bonus directly.

What to design instead

Section 26(1) permits offering other goods free or at a reduced price during the customer relationship, to maintain it. The benefit must not be contrary to good practice and must be moderate in value. Neither the amount of gambling nor not gambling may affect the grounds on which it is offered or what it is worth. The bill's examples (HE p. 301) are free or discounted event tickets, a service or a product.

On my reading in point 4, a match ticket is available where a deposit match is not. It cannot reward volume or target dormant players for being dormant. My reasoning: a gift for registering does not maintain a relationship, so section 26(1) does not cover it and section 52(13) applies.

Send it the same way as a retention bonus: direct, to an existing customer who passes the section 54 screens (for a bonus, the relationship must also be established under section 26(2)). On my reading, that is the lowest-risk route.

Next in this series

The two-year direct marketing rule in section 54.

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.

Gloria Kesa runs FinEst Verba (finestverba.com), writing and translating regulated-market content for the Finnish and Estonian markets. Finnish and Estonian are both her mother tongues, and she has translated legal texts since 2010. The full section-by-section reading of Chapter 4, with common marketing activities classified, is at https://finestverba.com/marketing-under-the-finnish-licence/. Her work is drafting, translation and written analysis; the decision stays with your counsel.

Sources: Rahapelilaki (Gambling Act 10/2026), sections 4, 25, 26, 34, 51, 52, 54, 55 and 106 (Finlex). HE 16/2025 vp. Administration Committee report HaVM 28/2025 vp. Ministry of the Interior, questions and answers on the gambling system reform. Nordia Law (Tuomas Pelkonen), Entering Finland's New iGaming Market: What Operators Need to Know, 3 December 2025. Advertising Finland, The Finnish gaming market is opening to competition: here's what we now know about the gambling reform, 12 May 2025, updated December 2025.