As Finland continues to iron out finer details of its gambling framework ahead of a 2026 launch, stakeholders remain fearful over the current direction being taken when it comes to affiliates and digital marketing.
The cogs of the new legislation will turn throughout the year ahead of the commercial market going live in July 2027. Sports betting and online casino licences will be issued from March, but Lotto, Eurojackpot and physical slot machines will remain under the control of the state-owned operator Veikkaus.
Final decisions will be made on several different components of legislation before the market launches, but alarm bells have been raised that the current direction of the marketing framework will have a major impact on the prosperity of smaller operators.
Digital direction
Jari Vähänen, co-founder and partner at The Finnish Gambling Consultants, believes marketing regulation is unclear at the moment and that it should be leaning more towards the digital scope.
“The legislation approved in December remains imprecise regarding marketing, so it isn’t easy to assess the marketing opportunities in the future license-based market for now,” noted Vähänen.
“According to my interpretation, large operators with sufficient funds to participate in ‘brand advertising competitions’ in mass media will have good business opportunities. On the other hand, the upcoming restrictions on digital marketing will pose challenges for smaller operators. Therefore, there is a risk that several companies will continue to operate in the black market.
“I would have liked to allow licensed companies to compete with modern digital marketing tools and would have preferred to limit mass media marketing, because it targets everyone, not just customers interested in gambling.”
Hippos ATG chief compliance officer, Antti Koivula, is in agreement with Vähänen that limitations in digital marketing could create significant issues in the newly regulated Finnish commercial market.
“My concern is that the new rules are fairly permissive for traditional mass media and sponsorships, but very strict for digital marketing. This creates two big problems.
“First, it pushes more marketing into mass media that people cannot really avoid, including minors and vulnerable groups. If the goal is to reduce harmful exposure, the logic should be the other way around: stricter limits on mass media, and a controlled but workable space for targeted, age-gated digital marketing.
“Second, digital marketing will not go away by prohibiting it. Affiliates, influencers, social media and other digital marketing channels will still exist. If licensed operators cannot use these channels, unlicensed operators will.
“Expecting these channels to stop targeting Finland is unrealistic unless enforcement becomes very strong, including across borders. And right now, that does not look likely. If legal operators cannot compete where people actually discover brands, channelisation will drop, and all the negative effects will follow.
“Overall, I am extremely worried that the current choices will do the opposite of what the reform is meant to achieve: they will help the black market, increase harm, and reduce channelisation.”
Marketing must be responsible
Last month, the country’s gambling bill achieved a bipartisan 158-9 vote to move away from a monopoly of Veikkaus to a regulated, licensed market. Only the President’s signature is required for the bill to become law.
Finland’s National Police Board will make licensing decisions before the Licensing and Supervision Agency takes over regulatory responsibilities in June this year. The process for B2B licences will begin in July next, with a licence becoming a requirement for the market by July 2028.
Koivula urged Finland to change lanes completely in terms of the marketing direction that the country is currently travelling in.
“The starting point is simple: licensed operators must be allowed to market enough so people can find them, compare them and choose them,” stated Koivula.
“If legal operators cannot be seen, demand will not disappear. It will move to the black market. That means less consumer protection, more harm and less tax income for the state.
“At the same time, marketing must be responsible. Finland should not repeat the trend we have already seen under the monopoly system, where gambling harms have grown rapidly. Minors and other vulnerable people must be protected. That requires clear and consistent rules that push marketing into places where exposure can be limited and checked.”
Affiliates may continue to operate with black market
Vähänen also believes that, despite the ban on affiliate marketing, promotions could still occur with black market operators.
“I believe the Finnish media will not accept advertising from black-market operators. At least this has been the case so far. Instead, I am terrified that affiliates will continue to operate, and black market operators will be their only customers, because licensed companies are not allowed to use affiliates.
“The success of the entire gambling system will depend on how the new regulator is able to prevent the business of companies operating without a Finnish license. Unfortunately, I am sceptical about this, but I hope I am wrong.”
Vähänen added that casino operators will be impacted by the ban on affiliate marketing, stating that 50% to 90% of customers are acquired through that channel. Other restrictions will affect operations as well.
“A considerable means is the use of welcome bonuses, which will also be prohibited under the new Finnish system. I assume that the current affiliates that attract Finnish customers will continue their operations and, in particular, direct Finnish casino customers to black market operators.
“This will probably not be as big a problem in the betting business. Influencers are a subcategory of affiliates. I myself would have been ready to ban influencers, but I would have liked to allow, for example, betting and, why not, casino comparison sites.”
The year ahead
Outstanding components that still need to be fine-tuned and clarified include secondary legislation, where game characteristics (e.g. autoplay, bonus buys), maximum stake levels, and game speed will be determined; technical regulations; as well as further guidance on certain key interpretative issues, particularly in areas such as marketing.
How these developments will be issued remains to be seen beyond the dates listed above, as Finland’s parliament will not reconvene until next month, with the election of the president and vice presidents on 3 February, the opening of the 2026 parliament the following day and an oral question and answer session taking place on 5 February.
With 2026 set to be a big year for Finland’s gambling future, what kind of marketing direction should be set out for the European market when commercial operators go live in July 2027?
This story was first published on Affiliate Leaders’ sister title, iGaming Expert.
