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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.

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 markets that license affiliates as a class. 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", and the regulator treats celebrity and influencer promotion as advertising within the ban. Affiliate marketing as promotion is prohibited; informational comparison content exists in a grey zone the regulator's guidelines have narrowed rather than closed. The market is large and the affiliate channel is, formally, almost absent.

Belgium has banned gambling advertising across public space, broadcast, social media and online since 2023, with the ban extending to affiliate marketing and further restrictions scheduled through 2028. Affiliate promotion to Belgian customers is not a compliance question; it is prohibited.

Lithuania adopted a general advertising ban from July 2025 with full enforcement earmarked for 2028, having already prohibited the promotion of bonuses and free bets on websites and review portals. Its regulator's prohibition on hyperlinking from online promotion to operators removed the affiliate mechanism itself.

Latvia prohibits direct gambling advertising across all media, and the affiliate channel operates, where it does, through indirect arrangements the authorities are actively examining.

The monopoly markets. Norway and, until its 2027 opening, Finland permit promotion only of the state operators; assisting the marketing of any other gambling to their residents is an offence, and both have prosecuted or fined streamers and site operators who linked to offshore casinos. Norway blocks at DNS level. Switzerland permits promotion only of its locally licensed operators and its courts have upheld blocks on unlicensed sites reached through search marketing. Poland confines affiliate activity to licensed sports betting and pursues sites linking to international casino operators.

The conditional regimes

The Netherlands does not license affiliates but imposes conditions that many cannot meet. Since 2023 the country bans "untargeted" gambling advertising; online advertising, including on affiliate sites, is permitted only where the advertiser can demonstrate that at least 95 per cent of the audience is 24 or older, and the burden of proof is on the party advertising. Role models (celebrities, athletes, influencers, models) may not appear in gambling advertising. The regulator, the KSA, ran an investigation into affiliate websites and news sites in 2025 and issued penalty orders. Operators are responsible for their affiliates' compliance under their licence conditions and have cut affiliate programmes accordingly.

Sweden regulates affiliates through the operator. The Gambling Act requires "moderation" in all gambling marketing, prohibits targeting of under-18s and of self-excluded people (the national scheme is Spelpaus), restricts bonuses to a single welcome offer, and makes the licensee answerable for marketing done on its behalf. Spelinspektionen has fined operators for affiliate content and expects them to contract with, approve and monitor affiliates.

Denmark likewise holds the operator responsible, with guidelines from Spillemyndigheden on affiliate marketing: identification of affiliates to the regulator on request, compliance with the marketing rules (including the national self-exclusion register ROFUS, responsible gambling messaging and bonus restrictions), and no promotion of unlicensed operators.

Germany permits online gambling under the 2021 State Treaty with strict advertising rules administered by the GGL: no advertising between 6am and 9pm for online slots and poker on broadcast and video, no targeting of minors or vulnerable people, restrictions on influencers, and a requirement that licensees ensure affiliates comply. The GGL has pursued affiliate sites promoting unlicensed operators, including through payment and hosting blocks.

Spain restricts gambling advertising under a 2020 royal decree: broadcast advertising confined to a late-night window, welcome bonuses advertised only to existing verified customers, no celebrities in advertising, and social-media promotion limited to followers over 18. Affiliate content falls within the rules, and the regulator has consulted on further restrictions on influencer promotion.

France licenses online betting and poker (not casino) and regulates advertising through the ANJ with a code that restricts content, targeting and influencer promotion; the ANJ has acted against affiliates and influencers promoting unlicensed casino to French residents and has blocked prediction-market venues.

Portugal, Greece, Czechia and the others each combine operator responsibility with national advertising rules of varying strictness, and each treats promotion of unlicensed operators to its residents as an offence.

The registration regimes

Romania licenses affiliates directly. Under its gambling law, entities that promote or advertise online gambling to Romanian players must hold a class II licence from the national office, ONJN, with fees and obligations of their own. Operators may pay only licensed affiliates, and the regulator publishes the list.

Malta does not license affiliates but requires its licensees to ensure that affiliates comply with Maltese marketing rules and with the laws of the markets targeted, and the MGA has taken action against licensees over affiliate conduct. Because Malta licenses so many international operators, its position reaches affiliates far beyond Malta.

Others. A small number of markets register or approve affiliates on application; more are considering it, on the American model, as the operator-responsibility approach shows its limits.

The patterns

Across the map, five things are consistent.

Bonus content is the most regulated content. Bans on advertising welcome bonuses (Sweden's single-offer rule, Spain's existing-customers-only rule, Lithuania's prohibition, the Netherlands' targeting proof) 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.

Influencers and streamers are the frontier. Every regulator that has updated its rules recently has addressed influencer promotion specifically, from outright bans (Belgium, Italy, the Netherlands' role-model rule) 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, promoting an operator that holds no local licence to that market's residents is illegal, and in the monopoly markets it has been prosecuted. Grey-market affiliate revenue in Europe is shrinking 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 sweep, the GGL's blocking, the ANJ's actions) and, in some cases, direct licensing.

Self-exclusion circumvention is the line. Every market with a national scheme treats content that helps excluded people find operators outside it as the worst affiliate conduct there is.

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 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 an offence everywhere; 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 prohibition since 2023 on gambling advertising that cannot be shown to reach an audience at least 95 per cent aged 24 or over, with the burden of proof on the advertiser.
Role-model ban
The Dutch prohibition on celebrities, athletes, influencers and models in gambling advertising.
Moderation duty
Sweden's statutory requirement that all gambling marketing be moderate, alongside a single-welcome-offer rule and a prohibition on targeting the self-excluded.
Class II licence
Romania's licence for entities that promote or advertise online gambling to Romanian players; operators may pay only licensed affiliates.
No-hyperlink rule
Lithuania's prohibition on linking from online promotion to operators, which removed the affiliate mechanism itself ahead of the general advertising ban.

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 advertiser can prove 95 per cent of the audience is 24 or older, and bans role models; its regulator swept affiliate sites in 2025.
  • Bonus content is the most regulated content in Europe, and welcome-offer promotion is prohibited or restricted market by market.
  • In the monopoly markets, assisting the marketing of any other gambling is an offence that has been prosecuted, including against streamers.
  • Romania licenses affiliates directly under a class II licence; Malta reaches affiliates through its licensees.

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 happened to streamers linking to offshore casinos in Finland and Norway?

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

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