Affiliates, Affiliates—and One More Time, Affiliates. Why Finland’s Proposed Ban Could Undermine Its Gambling Reform?

While the reform is broadly welcomed, one particular clause has drawn overwhelming attention—and concern: the proposed ban on affiliate marketing.

This single provision has the potential to derail the entire reform effort. It would drastically reduce the channelization rate, do very little to support the prevention of gambling-related harm, and in many ways contradicts the reform’s core objectives.

So why is this ban being proposed—and what are its real implications Here’s a candid and unfiltered look behind the policy.

A Policy Built on Misbeliefs

Let’s begin with a direct quote from the government’s proposal:

“The use of the affiliate marketing referred to in the provision as a marketing tool could cause irregularities with regard to the information to be provided in connection with marketing proposed in the proposed section 52 and blur the distinction between licence holders and illegal operators.”

The concern here is that affiliate-driven advertising might lead to omissions or misrepresentations—for example, missing age warnings or responsible gambling messages.

But why is this concern being directed only at affiliates?

In regulated markets elsewhere, affiliate websites are subject to the same compliance standards as all other advertising platforms. They must display legally required disclosures, include age and responsibility messaging, and follow advertising codes—just like newspapers, broadcasters, and digital media do.

Importantly, enforcement is typically handled by holding licensed operators responsible for their affiliates’ conduct. This approach works—and it works effectively. With proper oversight, the risk of irregularities can be mitigated. A blanket ban is not a proportionate response—it’s a blunt one.

The Myth of Blurred Lines

The proposal further claims that affiliate marketing could “blur the distinction between licence holders and illegal operators.”

This assumption does not withstand scrutiny.

In a well-regulated environment, reputable affiliates have every incentive to promote only licensed brands. Partnering with unlicensed operators would destroy their credibility, terminate their agreements with compliant companies, and eliminate their income. No serious affiliate would take that risk.

In reality, affiliate marketing serves the opposite function: it channels players toward legal, licensed gambling options—particularly when clear rules and accountability measures are in place. Far from undermining the system, affiliates are a critical part of making it work.

Performance-Based Marketing ≠ Irresponsibility

Another concern raised in the proposal is that affiliate models—because they involve commissions or revenue shares—might lead to aggressive or irresponsible marketing.

But this logic is flawed.

All advertising is performance-based to some extent. Whether it’s newspapers, online media, or television, ad pricing is tied to impressions, clicks, reach, or conversions. All use tracking mechanisms to monitor campaign effectiveness—just like affiliates.

If the concern is excessive incentives or rule violations, then set clear rules and enforce them. That’s what mature regulatory systems do. Banning the entire model, purely on the basis of how it operates, is not regulation—it’s overreaction. And one that could have serious strategic consequences.

Affiliate Websites Were Mistaken for Influencers

One of the most significant misconceptions influencing the current proposal appears to be a fundamental confusion between affiliate websites and social media influencers.

Influencer marketing—particularly from slot streamers and Instagram personalities—has been a source of concern for regulators for some time. In fact, the issue was addressed during the last legislative reform, when the National Police Board was granted new powers to supervise gambling advertising. Influencers, especially those targeting young or vulnerable audiences, have been under increased scrutiny—and rightly so.

But affiliate websites are not the same thing.

Unfortunately, it is now evident—both from the proposal itself and from behind-the-scenes conversations—that many decision-makers have mistakenly lumped affiliates and influencers together. The policy treats them as interchangeable, despite their vast operational and regulatory differences.

This confusion has heavily shaped the affiliate ban and led to a classic policy misstep: throwing the baby out with the bathwater.

A Legacy of Distrust

It’s time to acknowledge the elephant in the room: affiliate marketing has a reputation problem in Finland, and much of it is self-inflicted.

During the monopoly era, Finnish-facing affiliates commonly promoted offshore sites—because no domestic alternatives existed. That legacy casts a long shadow over the current debate.

Many of the same officials involved in today’s reform also shaped previous legislation, when affiliates were mainly as a source of illegal gambling marketing. Those perspectives are hard to shake. Old beliefs persist—even when circumstances have changed.

Who Stands to Gain?

Who stands to benefit from this ban? The answer is clear: traditional Finnish media.

Affiliates currently account typically for 60–90% of online customer acquisition in regulated markets. Remove them, and licensed operators will have no choice but to flood the few remaining legal channels—namely, mainstream media—with ads. Demand for space will spike, and so will prices.

To be clear, I’m not implying that media houses have lobbied for the ban. But they certainly have little to lose—and much to gain—from it. If anything, they’re now about to be handed nearly a monopoly over gambling marketing in 2027.

The risk? A repeat of Sweden in 2019, when a marketing blitz in mainstream media caused public backlash. And unlike Sweden, Finland’s proposal includes an affiliate ban—which means even fewer targeted options and more aggressive saturation of untargeted media. That’s a recipe for public resentment.

One has to wonder—will Finnish citizens be on board with the traditional media’s gambling ad bonanza in 2027, when every commercial break during “Salatut Elämät” and the seven o’clock news is flooded with gambling promotions, radio stations churn out brand slogans every ten minutes, and newspapers begin to resemble glossy gambling catalogues? This will no doubt suit traditional media just fine—but is it really what the citizens would want?

Time for Self-Reflection in Harm Prevention Circles

For years, gambling harm prevention actors in Finland have voiced strong opposition to affiliate marketing—often painting affiliate sites as predatory players targeting vulnerable individuals.

While I understand their rationale—that less marketing equals less gambling—their blanket opposition assumes a world where banning equals control. That might work in North Korea, where every aspect of life is state-run and disobedience is met with extreme punishment—but in a democratic society, things are far more nuanced.

What exactly is it about affiliate marketing that bothers them so deeply? I’ve had opportunities to challenge this view in discussions, and I still don’t understand the reasoning.

Ironically, many of the same voices that pushed hardest for the affiliate ban are now expressing concern about the result of their own advocacy: an inevitable flood of gambling ads in mainstream media.

Sometimes it’s worth pausing to consider the consequences of one’s actions—rather than simply calling for more restrictions, more bans, and more control.

Final Thoughts

Personally, I’m not a big fan of marketing. But like it or not, it plays a role in a functioning market—it helps consumers differentiate between legal and illegal offerings.

I don’t particularly favor affiliate marketing, nor do I celebrate traditional advertising. But here’s the difference: affiliate marketing is highly targeted. I don’t see it because I don’t search for gambling in Google. But traditional ads? No one can avoid them.

Ultimately, what matters is what’s best for the industry and the public. A ban on affiliates would harm the channelization rate, fuel a media saturation crisis, and risk turning the public against the entire reform. It could even become an election issue in 2027, leading to further restrictions.

In short, banning affiliates isn’t just a policy error—it’s a strategic misstep that could cost the reform its success. There’s still time to correct course. Let’s hope there’s enough political courage to do so.