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Lesson 4 of 7 · 16 min

Europe: From Bans to Licences

The bans (Italy, Belgium, Lithuania, Latvia, the monopolies), the conditional regimes (the Netherlands, Sweden, Denmark, Germany, Spain, France), Romania's licence, the five patterns, and the per-market permission matrix.

Fact-checked 23 September 2026 by iGaming Times editorial team · 34 sources

In this lesson

  • Place each European market in one of three categories: banned, conditional, licensed
  • Explain the Netherlands' 95 per cent over-24 proof and role-model ban, Sweden's moderation duty and single-bonus rule, and Romania's class II licence
  • Identify the five patterns across the map: bonuses, influencers, unlicensed promotion as an offence, operator responsibility plus direct action, the self-exclusion line
  • Maintain a per-market permission matrix and verify it on a schedule

A continent of different answers

Europe regulates gambling country by country, and affiliate marketing with it. The range runs from markets where gambling advertising, and therefore affiliate promotion, is banned almost entirely, through markets that permit it under strict conditions, to a market that licenses affiliates directly. An affiliate operating across Europe needs a country-by-country position, and this lesson provides the map: the bans, the conditional regimes, the registration regimes, and the patterns that connect them. Rules change frequently; every entry below should be checked against the regulator's current text before it is relied on.

The bans

Italy prohibited almost all gambling advertising and sponsorship in 2018 under the "Dignity Decree": Article 9 of Decree-Law 87/2018 bans any form of advertising, even indirect, for games and bets with cash prizes, on any medium including social media, and extended the ban to sponsorship from 1 January 2019. Fines, imposed by the communications regulator AGCOM, fall on the party commissioning the advertising and on the owner of the medium or site, at 20 per cent of the value of the advertising and at least €50,000 per breach. AGCOM's 2019 guidelines list advertising by influencers, direct and indirect, among the prohibited forms, while treating restrained, non-misleading comparison of odds or offers as information rather than advertising. Affiliate marketing as promotion is prohibited; informational comparison content exists in that narrow space. The market is large and the affiliate channel is, formally, almost absent.

Belgium has restricted gambling advertising under a royal decree in force since 1 July 2023, which also cuts back sports sponsorship in stages to 2028. Online, licensees may advertise on their own websites and social-media accounts and, beyond that, only by brand name or logo in paid search results shown for gambling-related searches, and adverts may not depict real people or fictional characters. The Gaming Commission states that affiliate websites advertising licensed sites are allowed only within those Article 10 conditions. Affiliate promotion to Belgian customers is therefore a narrow, search-led channel, not a mass-market one.

Lithuania restricted gambling advertising from 1 July 2025 as a transition to a full ban from 2028: in the meantime operators may show their name and trade marks only at their premises and on their own websites, only betting may be advertised on television, radio and online, in short spots capped per hour, and online betting adverts may not link to operators' websites. That no-link rule removes the affiliate mechanism itself.

Latvia's gambling law prohibits advertising of gambling and interactive gambling websites outside gambling venues, although experts, including the Latvian Advertising Association, told Latvian public radio in 2023 that the ban was not being enforced, with gambling adverts appearing on internet portals and television. Amendments in force from 1 April 2026 allow licensed betting operators' registered figurative trade marks in adult sport and move supervision from the Lotteries and Gambling Supervision Inspection to the State Revenue Service; the affiliate channel operates, where it does, through indirect arrangements.

The monopoly markets. In Norway only Norsk Tipping, Norsk Rikstoto and others holding a permit may market gambling, and the regulator treats links and affiliate agreements that bring unlicensed games to Norwegian players as prohibited marketing; it has ordered the company behind a casino brand, and the companies of the Norwegian streamers it used, to stop, with coercive fines and infringement penalties available. Norway has blocked unlicensed gambling sites at DNS level since 1 January 2025. In Finland no company other than Veikkaus may run or market gambling games until the end of June 2027; licensed competition in online betting and casino starts on 1 July 2027, under an act that prohibits influencer marketing. Switzerland bans advertising for games not authorised in Switzerland, makes it a punishable offence and requires access to unauthorised online games to be blocked. Poland prohibits the advertising and promotion of casino-type games, such as roulette, card and dice games and slot machines, allows licensed betting to be advertised under set conditions, and extends the ban to anyone who places an advert or profits from it, and its Ministry of Finance keeps a register of domains offering gambling unlawfully.

The conditional regimes

The Netherlands does not license affiliates but imposes conditions that many cannot meet. Since 1 July 2023 the country has banned "untargeted" advertising for online gambling: television, radio, print and public-space advertising are prohibited, and online advertising is permitted only where the licensee can show, using the best available techniques, that at least 95 per cent of the people reached were 24 or older. The decree defines a licensee's advertising as including advertising done with the help of third parties, so the burden of proof covers affiliate placements too. Role models, including influencers, streamers, athletes and models, may not be used to promote online gambling. In July 2025 the regulator, the KSA, announced a structural crackdown on paid news articles that steer readers to casinos outside Cruks, the national self-exclusion register, including an investigation into the marketing agencies that sell them.

Sweden regulates affiliates through the operator and the criminal law. The Gambling Act requires "moderation" in all gambling marketing, prohibits marketing aimed specifically at under-18s and direct marketing to people who have self-excluded (the national scheme is Spelpaus), and allows a bonus only on the first occasion a player plays with a licensee. Promoting participation in unlicensed gambling is an offence under the Act, and Spelinspektionen states that promoting unlicensed operators through marketing or affiliate links is prohibited; in the second half of 2025 it handled nine supervisory cases on the promotion of illegal gambling.

Denmark likewise works through the operator. Spillemyndigheden states that the general consumer-protection and marketing rules, and the Gambling Act's rules on marketing and intermediation, apply to affiliates too, and in January 2025 it warned operators that affiliate agreements can be used to launder money and should be reflected in their risk assessments. Affiliate content therefore has to meet the same marketing rules as the operator's own. Denmark also runs a national self-exclusion register, ROFUS, and an affiliate should treat responsible gambling and the register as part of any Danish campaign.

Germany permits online gambling under the 2021 State Treaty with strict advertising rules administered by the GGL: no advertising on broadcast or the internet between 6am and 9pm for virtual slots, online poker and online casino games, no advertising aimed at minors or comparable at-risk groups, no sports-betting advertising featuring active athletes or officials, and a ban on advertising unauthorised gambling. One rule is aimed squarely at affiliates: for online advertising, including affiliate links, for games covered by the national exclusion system, no variable remuneration, such as revenue share or commission based on deposits or stakes, may be agreed or paid. The GGL says its enforcement increasingly reaches beyond illegal operators to payment providers, advertising partners, affiliate networks and hosting providers, and by the end of 2025 it had checked about 6,300 websites for illegal gambling or advertising for it.

Spain restricts gambling advertising under Royal Decree 958/2020: audiovisual advertising is confined to 1am to 5am, and the decree applies expressly to anyone who spreads commercial communications, naming affiliates alongside websites and social networks. In April 2024 the Supreme Court annulled several of its restrictions for lack of a legal basis, including the limits on promotions aimed at new customers, the ban on well-known people in advertising, a general restriction on commercial communications through online information-society services, and the rules limiting advertising on social networks and video-sharing platforms. Affiliate content falls within the rules that remain, and the annulments are a reminder to check which provisions are in force.

France licenses online betting and poker (casino games remain prohibited online) and regulates advertising through the ANJ. Advertising an unauthorised gambling site is a criminal offence punishable by a €100,000 fine; since 2022 the ANJ can order internet providers and search engines to block or delist sites that offer or advertise illegal gambling, it is working with social networks against influencers who promote illegal casino sites, and in July 2026 it used its blocking power against the prediction-market site Polymarket.

Portugal, Greece, Czechia and the others combine operator responsibility with national advertising rules of varying strictness; check each one individually, including whether promoting an unlicensed operator to its residents is a criminal offence.

The registration regimes

Romania licenses affiliates directly. The national office, ONJN, states that affiliates, like software and payment providers, must apply for their own licence and that operators may work only with licensed partners. The licence is the class II licence for connected activities, which ONJN began issuing when Government Decision 111/2016 took effect, and the regulator publishes the list of class II licensees.

Malta does not license affiliates, but the MGA's commercial communications guidelines apply to anyone providing marketing services on a licensee's behalf, and where an affiliate sends promotional material for a licensee, both the affiliate and the licensee may be held in breach. Promoting or facilitating an unauthorised gaming activity can lead to criminal prosecution. Because Malta licenses so many international operators, its position reaches affiliates far beyond Malta.

Others. In the other markets covered here, regulators reach affiliates through the operator, through advertising rules that bind whoever publishes (Italy's fines fall on site owners, Poland's ban covers anyone who places an advert or profits from it) or through the payment model (Germany's ban on revenue share).

The patterns

Across the map, five things are consistent.

Bonus content is the most regulated content. Bonus rules (Sweden's first-occasion-only rule, the Dutch ban on aiming bonuses at vulnerable groups, including young adults, and the Belgian and Lithuanian limits on what may be advertised at all) remove the affiliate industry's main conversion tool market by market, and an affiliate's European strategy has to work without it in most places. Spain shows the rules can also move the other way: its Supreme Court annulled the decree's limits on new-customer promotions in 2024.

Influencers and streamers are the frontier. Most regulators that have updated their rules recently have addressed influencer promotion specifically, from outright bans (the Netherlands' role-model rule, Finland's new act, Italy's guidelines, Belgium's ban on depicting people) to disclosure and age requirements. The affiliate that relies on creators in Europe is relying on the channel regulators are closing.

Unlicensed promotion is an offence, not a breach. In every market above, advertising an operator that holds no local licence falls outside what is permitted, and in several, including Sweden, Switzerland, France and Malta, it is a criminal offence; Norway has ordered streamers and the companies behind them to stop. Grey-market affiliate work in Europe carries more risk each year because the grey is turning black.

Operator responsibility is being supplemented, not replaced. The regulators that rely on operators to police affiliates are adding their own investigations (the KSA's 2025 action on paid news articles, the GGL's action against affiliate networks and hosting providers, the ANJ's blocking orders) and, in Romania, direct licensing.

Self-exclusion circumvention is the line. Markets with a national scheme treat content that helps excluded people find operators outside it as the worst affiliate conduct there is; the Dutch regulator's 2025 action against articles promoting casinos outside Cruks is one example.

A European permission matrix

An affiliate active in Europe maintains, per market: whether promotion is permitted at all; which products (casino, betting, poker, lottery); whether bonuses may be shown and to whom; the age and vulnerability rules; the influencer rules; whether the affiliate needs a licence or registration; the national self-exclusion scheme and the obligation not to circumvent it; the regulator's identification and reporting expectations; and the date the entry was last verified. The matrix drives the page template for each market, the approval workflow and the list of operators that may be promoted, and it is the document an operator's compliance team will ask to see.

What to take from this lesson

Europe ranges from outright or near-total bans (Italy, Belgium, Lithuania, the monopoly markets) through conditional regimes (the Netherlands' targeting proof and role-model ban, Sweden's moderation and single-bonus rule, Germany's GGL rules, Spain's decree, France's ANJ code) to direct licensing (Romania's class II licence). Bonus content and influencer promotion are the most restricted; unlicensed promotion is prohibited everywhere and a crime in many markets; and self-exclusion circumvention is the line nobody crosses. Maintain a per-market permission matrix, verify it on a schedule, and build each market's template from it.

Key terms

Untargeted advertising ban
The Dutch ban, in force since 1 July 2023, on untargeted advertising for online gambling: broadcast, print and public-space adverts are prohibited, and online adverts are allowed only where the licensee can show that at least 95 per cent of those reached were 24 or older.
Role-model ban
The Dutch prohibition on using role models, such as influencers, streamers, athletes and models, to promote online gambling.
Moderation duty
Sweden's statutory requirement that all gambling marketing be moderate, alongside a rule that a bonus may be offered only on a player's first occasion with a licensee and a ban on direct marketing to self-excluded players.
Class II licence
Romania's licence for connected activities in gambling, which affiliates, software and payment providers must hold; licensed operators may work only with licensed partners.
No-hyperlink rule
Lithuania's rule, in force from July 2025, that online betting adverts may not link to an operator's website, which removes the affiliate mechanism itself ahead of the full advertising ban from 2028.

Key takeaways

  • Europe ranges from outright advertising bans through conditional regimes to direct affiliate licensing, and every entry must be checked against the regulator's current text.
  • The Netherlands permits online gambling advertising only where the licensee can prove that 95 per cent of those reached were 24 or older, and bans role models; in 2025 its regulator moved against paid articles promoting casinos outside the Cruks self-exclusion register.
  • Bonus content is the most regulated content in Europe, and welcome-offer promotion is prohibited or restricted market by market, though Spain's Supreme Court annulled its new-customer limits in 2024.
  • In the monopoly markets, promoting any other gambling is prohibited, and Norway's regulator has ordered streamers and the companies behind them to stop.
  • Romania licenses affiliates directly under a class II licence; Malta reaches affiliates through its licensees and can hold both in breach.

Sources

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

  1. Decree-Law 12 July 2018 no. 87, Article 9: ban on advertising games and bets, Normattiva (Italian Government), accessed 2026-09-23
  2. Delibera 132/19/CONS, Annex A: guidelines on Article 9 of the Dignity Decree, AGCOM, accessed 2026-09-23
  3. Royal Decree of 27 February 2023 on the rules for advertising games of chance, Belgian Official Gazette (via etaamb.openjustice.be), accessed 2026-09-23
  4. RD advertising: interpretation of the Royal Decree of 27 February 2023, Belgian Gaming Commission, accessed 2026-09-23
  5. Gambling advertising restrictions take effect, in force until the full ban in 2028, LRT, accessed 2026-09-23
  6. Changes in the Latvian gambling regulation, NJORD Law Firm, accessed 2026-09-23
  7. Latvia's ban on gambling ads only a formality, say authorities, LSM (Latvian Public Broadcasting), accessed 2026-09-23
  8. Mye av pengespillreklamen du ser er ulovlig, Norwegian Gaming Authority (Lottstift), accessed 2026-09-23
  9. Schpell og fleire influensarar må stanse ulovleg marknadsføring av pengespel i Noreg, Norwegian Gaming Authority (Lottstift), accessed 2026-09-23
  10. Blokkering av ulovlige pengespillsider, Norwegian Gaming Authority (Lottstift), accessed 2026-09-23
  11. Finland to open some gambling services to competition, Finnish Government, accessed 2026-09-23
  12. Federal Act on Gambling (Geldspielgesetz), SR 935.51, Articles 74, 86 and 131, Fedlex, Swiss Confederation, accessed 2026-09-23
  13. Ustawa o grach hazardowych, Art. 29: advertising and promotion prohibitions, LexLege, accessed 2026-09-23
  14. Rejestr Domen Służących do Oferowania Gier Hazardowych Niezgodnie z Ustawą, Ministry of Finance, Poland, accessed 2026-09-23
  15. Besluit werving, reclame en verslavingspreventie kansspelen, wetten.overheid.nl, accessed 2026-09-23
  16. Belangrijkste regels voor kansspelreclame, Kansspelautoriteit, accessed 2026-09-23
  17. Strenge regels voor de inzet van rolmodellen, Kansspelautoriteit, accessed 2026-09-23
  18. Kansspelautoriteit pakt promotie illegaal aanbod via nieuwsbladen structureel aan (15 July 2025), Kansspelautoriteit, accessed 2026-09-23
  19. Verbod op ongerichte reclame per 1 juli, Kansspelautoriteit, accessed 2026-09-23
  20. Spellag (2018:1138), Sveriges riksdag, accessed 2026-09-23
  21. Spelpaus.se, Spelinspektionen, accessed 2026-09-23
  22. Vad är olaglig spelverksamhet, Spelinspektionen, accessed 2026-09-23
  23. Nyhetsarkiv olagligt spel, Spelinspektionen, accessed 2026-09-23
  24. Spillemyndigheden gør opmærksom på hvidvaskrisiko ved brug af affiliates (9 January 2025), Spillemyndigheden, accessed 2026-09-23
  25. Glücksspielstaatsvertrag 2021, § 5 Werbung, REVOSax, Free State of Saxony, accessed 2026-09-23
  26. Fünf Jahre GGL: Fachbehörde hat sich etabliert und ist wirksam, Gemeinsame Glücksspielbehörde der Länder, accessed 2026-09-23
  27. Real Decreto 958/2020, de comunicaciones comerciales de las actividades de juego (consolidated), Boletín Oficial del Estado, accessed 2026-09-23
  28. El Tribunal Supremo anula varios artículos del Real Decreto 958/2020 (10 April 2024), Consejo General del Poder Judicial, accessed 2026-09-23
  29. Lutter contre l'offre illégale, Autorité nationale des jeux, accessed 2026-09-23
  30. Promotion d'une offre de jeux d'argent illégale : blocage du site Polymarket, Autorité nationale des jeux, accessed 2026-09-23
  31. FAQ, section 9: B2B licences for software providers, affiliates and payment providers, Oficiul Național pentru Jocuri de Noroc, accessed 2026-09-23
  32. Class II licences for connected activities in remote gambling, Oficiul Național pentru Jocuri de Noroc, accessed 2026-09-23
  33. List of class II licensed operators, Oficiul Național pentru Jocuri de Noroc, accessed 2026-09-23
  34. Commercial Communications Committee Guidelines, Malta Gaming Authority, accessed 2026-09-23

Check your understanding

4 questions · answer them all, then check.

  1. 1. What must an affiliate show to advertise gambling online to Dutch customers?

  2. 2. Which European market licenses affiliates as a class?

  3. 3. What has Norway's regulator done about Norwegian streamers who promoted an offshore casino brand?

  4. 4. Which content is most restricted across the European map?

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