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Lesson 7 of 7 · 16 min

Building the Affiliate Compliance Function

The components, from ownership and the permission matrix to records; scaling from one site to a group; accreditation and industry standards; what operators ask at onboarding; and where the rules are going.

Fact-checked 23 September 2026 by iGaming Times editorial team · 16 sources

In this lesson

  • Build the function: ownership, permission matrix, templates and standard, review workflow, monitoring, licensing register, channel and partner inventory, data protection, training, records
  • Scale it with markets and channels rather than revenue
  • Use accreditation and industry codes to verify the function, not replace it
  • Answer an operator's onboarding questionnaire in a day and read the five directions the rules are taking

The function that keeps the business

An affiliate's compliance function is not a cost of doing business in regulated markets; it is the thing that makes the business possible there, because licensed operators will not pay an affiliate that cannot demonstrate one and regulators will not license an affiliate that does not have one. In Britain, for example, the operator's licence makes it responsible for the third parties it contracts with, and its contracts must require the affiliate to behave as if bound by the same licence conditions. This lesson sets out what the function consists of, how it scales from a single site to a listed group, the accreditation and industry-standards landscape around it, what operators ask for in due diligence, and where the rules are heading.

The components

Ownership. Someone is responsible. In a small affiliate it is the founder with an hour a week and a checklist; in a large one it is a head of compliance with a team. Regulators and operators both ask who, and "everyone" is the wrong answer.

The permission matrix. The document at the centre of the function: for every market the affiliate operates in, whether promotion is permitted, which products, which operators (licensed there), whether bonuses may be shown and to whom, the age and vulnerability rules, the influencer rules, the licence or registration the affiliate holds, the national self-exclusion scheme, the mandatory page elements, and the date last verified. Lessons two to five are the content of the matrix; the matrix is what turns them into operations.

Templates and the content standard. Page templates per market that carry the mandatory elements automatically; a written content standard covering disclosure, bonus rendering, prohibited claims, prohibited imagery and responsible gambling messaging; and a bonus and terms database that is the single source of every offer shown.

The review workflow. Compliance as a step in content production: every new or changed page in a regulated market checked against the market's rules before publication, with the operator approval process where the agreement requires it, and a record of who checked what.

Monitoring. A crawl of the affiliate's own properties, across every channel, for prohibited terms, stale offers, missing elements and market leakage, with findings logged and fixed. Monthly at minimum; weekly for bonus content.

Licensing. A register of every licence and registration held, with renewal dates, fees, filing obligations and change-of-ownership triggers, and a calendar that produces the filings on time. In the United States this is a programme in its own right.

Channels and partners. An inventory of every channel the affiliate uses (sites, newsletters, social accounts, video, streams, apps, communities) and every partner (sub-affiliates, creators, traffic vendors, media partners), each bound to the same standards, each monitored, each terminable.

Data protection. Consent management, privacy notices, data agreements with operators, email consent and suppression, and a record of processing. Suppression matters most for self-excluded people: in Britain the Commission and the Information Commissioner's Office hold the operator primarily responsible if an affiliate's direct marketing reaches them, so operators check it.

Training. Writers, editors and anyone who publishes or promotes know the rules for the markets they work in and where to find the matrix.

Records. Everything above produces a paper trail, and the paper trail is the function's product: it is what an operator's audit, a regulator's enquiry and a buyer's due diligence ask for.

Scaling the function

A single-market affiliate with one site can run all of the above in a spreadsheet, a checklist and a monthly afternoon, provided it actually does. A multi-market affiliate needs the matrix as a maintained document, a compliance owner, template-driven publishing and an automated crawl. A licensed American affiliate needs a licensing programme with counsel. A listed group needs a compliance department, a board-level report and, increasingly, external accreditation. The principle is constant: the function scales with the number of markets and channels, not with revenue, and an affiliate that adds a market without adding to the function has added a liability.

Accreditation and industry standards

The affiliate industry has responded to regulation with standards of its own, and they have become part of what operators look for.

Responsible marketing accreditation schemes assess an affiliate's sites and processes against a code covering disclosure, responsible gambling messaging, age controls, bonus presentation and unlicensed promotion, and award a mark or a pass on completion. In Britain, Responsible Affiliates in Gambling, a trade association founded in 2019 by Racing Post, Oddschecker and Better Collective, makes an independent annual social responsibility audit a condition of membership. An audit report of that kind is evidence an operator can ask to see.

Affiliate associations with responsible-gambling codes have formed in Britain and the United States. Responsible Affiliates in Gambling commits members to the CAP and BCAP codes, the industry's responsible advertising code and ASA guidance on affiliate marketing; the Responsible Gambling Affiliate Association, founded in the United States in November 2023 by six affiliate groups, lists advertising codes of conduct and steering consumers towards locally licensed operators among its pillars, and aims to give affiliates a voice in shaping sensible regulation. Membership signals a position and provides a framework.

Operator programmes have their own codes, onboarding questionnaires and audits. In Britain these rest on a licence condition: the operator's contract must oblige the affiliate to provide the information the operator needs to meet its own reporting duties, and allow prompt termination if the affiliate breaches an advertising code.

Regulators remain the final word, and in markets weighing direct licensing, an audited, self-regulating affiliate sector is one argument the industry can make that licensing is not needed.

Accreditation does not replace the function; it verifies it. An affiliate that builds the function described above will pass accreditation; one that seeks accreditation as a substitute will not.

What operators ask for

Onboarding with a licensed operator in a regulated market now involves a compliance questionnaire, and the questions are consistent enough to prepare for.

Legal entity, ownership and key people, with identification. Every site, domain, channel and sub-affiliate. Licences and registrations held, by market. The markets the affiliate promotes into and the basis on which it may. The content standard, the review workflow and evidence of it. The monitoring process and recent reports. The disclosure practice. The bonus rendering and update process. The data-protection arrangements. Whether the affiliate promotes unlicensed operators anywhere, and whether it has ever been terminated by an operator or sanctioned by a regulator, and why. References from other operators. Accreditation held.

An affiliate that can answer all of it in a day is onboarded; one that cannot may not be, or may be offered only flat-fee terms with no revenue share and little trust.

Where the rules are going

Five directions, visible across every market in this course.

Direct licensing is spreading. The American model, in which the affiliate is licensed and directly accountable (in Pennsylvania, an affiliate paid a revenue share must be certified and one paid a flat fee registered), is an option for regulators who find operator responsibility insufficient. Romania has it: affiliates need a Class 2 licence from the national gambling office, ONJN, and must send it their contracts with operators. Others are watching.

Bonuses are leaving the affiliate channel. Brazil barred operators from granting any bonus or advance for a bet before prohibiting fixed-odds betting outright in September 2026; Ontario prohibits advertising inducements, bonuses and credits except on the operator's own site and in consented direct marketing; Sweden allows a bonus only on a player's first gaming occasion; and Lithuania legislated a ban on gambling advertising from July 2025, with a transition for sport until 2028. Britain's licence conditions now cap bonus wagering requirements at ten times and bar incentives that mix gambling products. The trend is not one way: Spain's Supreme Court annulled parts of the 2020 advertising decree's rules on promotions in April 2024. Even so, affiliate models built on offers are being regulated out of the newest and strictest markets.

Creators are being named. Recent rule sets address influencers specifically: Ontario bars influencers and celebrities likely to appeal to minors, and athletes with an operator or supplier arrangement except to advocate responsible gambling, and Romania has since 7 October 2025 prohibited broadcast gambling advertising featuring public or sports personalities, or people whose online notoriety may encourage play. The affiliate that uses creators needs a creator compliance process now and should expect the channel to keep shrinking.

Unlicensed promotion is being prosecuted. From cease-and-desist letters to fines and prosecutions, promoting unlicensed gambling is treated as an offence rather than a contractual breach. In Britain advertising unlawful gambling is a criminal offence under section 330 of the Gambling Act 2005, and an affiliate's grey-market history is now a liability in every licensed market.

Products are the new battleground. Sweepstakes casinos, prediction markets and crypto casinos are products affiliates are asked to promote where the legal status is least settled. California's AB 831, signed in October 2025, makes it a misdemeanour for a media affiliate knowingly to support the promotion of an online sweepstakes game in the state. An affiliate's product policy per market is now as important as its operator policy.

What to take from this course

Affiliates are regulated through the operator's licence or through their own, and in either case an affiliate in a regulated market must follow the market's marketing rules, be identifiable and accept oversight. Britain's regime (contract, approve, monitor, identify, terminate; the CAP Code; disclosure; no self-exclusion circumvention) is the reference. American states such as Pennsylvania license affiliates directly on a compensation test, state by state, and the live frontier is sweepstakes and prediction markets. Europe ranges from bans to conditional regimes to Romania's licence, with bonuses and influencers the most restricted content. Brazil, Ontario and Australia, where New South Wales makes it an offence to publish any inducement to gamble or to open a betting account, show the direction: no public inducements, named influencer rules, and content rather than offers as the product. Control runs through contracts, approval, monitoring and enforcement, with data protection across all of it. The compliance function, owned, documented, template-driven and monitored, with a permission matrix at its centre, is the licence to be in the business, and the affiliates that treat it that way are the ones operators still pay.

Key terms

Permission matrix
Per market: whether promotion is permitted, which products and operators, bonus rules, age and vulnerability rules, influencer rules, licence held, self-exclusion scheme, mandatory elements, last verified.
Licensing register
Every licence and registration held, with renewal dates, fees, filings and change-of-ownership triggers, driving a compliance calendar.
Channel inventory
Every property and partner the affiliate uses (sites, newsletters, social, video, streams, apps, sub-affiliates, creators, vendors), each bound to the standard and monitored.
Responsible marketing accreditation
An external assessment or audit of an affiliate's sites and processes against a code on disclosure, responsible gambling, age, bonus presentation and licensed-only promotion. In Britain, Responsible Affiliates in Gambling makes an annual independent social responsibility audit a condition of membership.
Onboarding questionnaire
The compliance questions a licensed operator asks before paying an affiliate: entity, channels, licences, markets, standards, monitoring, disclosure, data, history, references.

Key takeaways

  • The permission matrix is the centre of the function: it turns the rules of lessons two to five into operations.
  • The function scales with the number of markets and channels; adding a market without adding to it adds a liability.
  • Accreditation verifies a function that exists; it does not substitute for one.
  • An affiliate that can answer the onboarding questionnaire in a day is onboarded; one that cannot may be offered only flat fees, or nothing.
  • Direct licensing is spreading, bonuses are leaving the channel, creators are being named, unlicensed promotion is being prosecuted, and products are the new battleground.

Sources

The legislation, regulator material and research this lesson was checked against.

  1. Licence Conditions and Codes of Practice: SR code 1.1.2 (responsibility for third parties) and 5.1.1 (rewards and bonuses), Gambling Commission, accessed 2026-09-23
  2. Affiliates or third parties: direct marketing and self-excluded customers, Gambling Commission, accessed 2026-09-23
  3. Gambling Act 2005, section 330: advertising unlawful gambling, legislation.gov.uk, accessed 2026-09-23
  4. 58 Pa. Code § 807a.1, interactive gaming service provider certification and registration, Pennsylvania Code and Bulletin, accessed 2026-09-23
  5. Registrar's Standards for Internet Gaming, Standards 2.03 and 2.05, Alcohol and Gaming Commission of Ontario, accessed 2026-09-23
  6. Lei nº 14.790, de 29 de dezembro de 2023, art. 29, Presidência da República (Brazil), accessed 2026-09-23
  7. Spellag (2018:1138), 14 kap. 9 § Bonuserbjudanden, Sveriges riksdag, accessed 2026-09-23
  8. Sentencia de 2 de abril de 2024, Tribunal Supremo, contra el Real Decreto 958/2020 (BOE-A-2024-10500), Boletín Oficial del Estado, accessed 2026-09-23
  9. AB 831 (2025), Gambling: operation of a contest or sweepstakes, chaptered text, California Legislative Information, accessed 2026-09-23
  10. Gambling advertising: inducements must not be advertised, NSW Government, Liquor & Gaming NSW, accessed 2026-09-23
  11. Gaming Law 2025: Romania, Law and Practice (WH Simion & Partners), Chambers and Partners, accessed 2026-09-23
  12. Lithuania to ban gambling ads, LRT (BNS), accessed 2026-09-23
  13. Responsible Affiliates in Gambling introduces social responsibility audit, Responsible Affiliates in Gambling, accessed 2026-09-23
  14. Code of Conduct, Responsible Affiliates in Gambling, accessed 2026-09-23
  15. Gambling affiliates create new group to protect consumers: Responsible Gambling Affiliate Association, PR Newswire (RGAA), accessed 2026-09-23
  16. Medida Provisória nº 1.394/2026: entenda as novas regras para as apostas de quota fixa, Secretaria de Prêmios e Apostas, Ministério da Fazenda, accessed 2026-10-16

Check your understanding

4 questions · answer them all, then check.

  1. 1. What is the single document at the centre of an affiliate compliance function?

  2. 2. How does the compliance function scale?

  3. 3. What is the relationship between accreditation and the function?

  4. 4. Which is NOT one of the five directions the rules are taking?

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