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Lesson 2 of 7 · 16 min

The United Kingdom

The licence conditions, the CAP Code's gambling rules, disclosure, the self-exclusion pages, the White Paper changes, what the Commission has said about affiliates, and what a British-facing affiliate does.

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

In this lesson

  • Set out what the Gambling Commission expects an operator to do about affiliates: contract, approve, monitor, identify, terminate
  • Apply the CAP Code's gambling rules to affiliate content: significant conditions, strong appeal, irresponsible messaging, disclosure
  • Explain why self-exclusion circumvention pages end relationships instantly
  • Run a British compliance process without holding a British licence

The reference regime

Britain regulates affiliates through the operator, and it did so early and visibly. The Gambling Commission's licence conditions make an operator responsible for the actions of the third parties it contracts with; the advertising codes apply to that marketing regardless of who produced it, and the ASA has said that primary responsibility for affiliate marketing remains with the gambling operator; and the Commission's published guidance and enforcement have told operators what it expects them to do about affiliates. An affiliate serving British customers, or hoping to be paid by a British-licensed operator, works inside that framework whether or not it has read it.

The licence conditions

The Licence Conditions and Codes of Practice (LCCP) make a licensee responsible for the third parties it contracts with (social responsibility code 1.1.2). Its contracts must require them to act as if bound by the same licence conditions and codes of practice, which include the duty to comply with the CAP and BCAP advertising codes (code 5.1.6), and must let the licensee terminate promptly where an affiliate has breached an advertising code. The Commission also expects due diligence on third parties and sufficient oversight and controls over them, and warns that failing to control them can lead to suspension or loss of the operating licence. In practice an operator meets these duties by:

Holding a written contract with every affiliate that sets out the compliance obligations and the operator's right to terminate for breach.

Approving affiliate marketing before it is published, or operating a process that achieves the same control.

Monitoring affiliate marketing on an ongoing basis, with evidence that it does so.

Knowing who its affiliates are, including sub-affiliates, and being able to produce the list.

Terminating affiliates that breach the rules and, where the breach is serious, reporting it: the Commission expects any marketing sent to self-excluded customers by an operator or one of its affiliates to be reported as a key event.

The Commission's guidance amounts to this: "we told the affiliate the rules" is not compliance; "we checked, found the breach and acted" is. On affiliate direct marketing it considers the operator primarily responsible for any breaches, and it is unlikely to accept that an operator took all reasonable steps where a single point of failure let marketing reach self-excluded people. The industry's own advertising code asks operators to put every affiliate through due diligence and sanctions checks, and to end relationships with affiliates that do not comply, preferably on a one-strike basis.

The advertising codes

The content rules come from the CAP Code (non-broadcast, which covers websites, social and email) and the BCAP Code (broadcast), administered by the Advertising Standards Authority. The CAP Code's gambling section expressly covers affiliate marketers acting on an operator's behalf, and the Commission's conditions make compliance with both codes a licence requirement. The recurring rules for affiliate content:

Significant conditions. Under CAP rule 8.17 any offer must clearly and prominently state its significant conditions (eligibility, qualifying deposit or wagering requirements, time limits, and restrictions on the bets or games that qualify) in the ad itself wherever leaving them out is likely to mislead, with the full terms usually one click away. The LCCP separately requires significant conditions at the point of sale and on any advertising for the offer. A bonus without its conditions is one of the main affiliate risks the ASA warns operators about.

No appeal to under-18s. Since 1 October 2022 the test is whether content has "strong appeal" to under-18s (CAP rule 16.3.12), which rules out topflight footballers, sportspeople, reality stars and influencers popular with under-18s, video game references and other imagery with youth appeal. The ASA has applied the test to social content, including Instagram posts by Oddschecker featuring Harry Kane and Erling Haaland, and the Commission expects operators to apply the codes' principles even to social content outside the ASA's remit.

No irresponsible messaging. No suggestion that gambling solves financial or personal problems, enhances personal qualities or is a way to achieve financial security; and, under CAP's guidance, no trivialising, no undue pressure or urgency such as "Bet now!", and no portrayal of problem behaviours such as chasing losses.

Responsible gambling and age. The Gambling Industry Code for Socially Responsible Advertising, which the LCCP tells licensees to follow, requires 18-plus and safer-gambling messaging across its advertising formats, and it expects operators to make their affiliates follow it by contract; affiliate pages that omit them are likely to fail the operator's audit.

Not misleading. Consumer law, now the Digital Markets, Competition and Consumers Act 2024, which the LCCP applies to licensees' marketing, and the code both prohibit misleading claims, and CAP rule 3.7 requires documentary evidence for objective claims: "best odds", "fastest withdrawals", "most trusted", unless they can be proved.

Disclosure

An affiliate review site in Britain must make clear that it is paid by the operators it reviews. The ASA treats affiliate content as marketing that must be obviously identifiable as such (CAP rule 2.1), and failing to make commercial intent clear is a practice banned outright by Schedule 20 of the Digital Markets, Competition and Consumers Act 2024, which CAP rule 2.3 reflects. The disclosure belongs near the content, not in a footer: the ASA recommends a label such as "Ad" placed prominently enough to be seen, and the industry code asks for affiliate ads to be marked "#ad".

The self-exclusion pages

The most damaging affiliate practice in Britain is the page built around "casinos not on GAMSTOP", the national online self-exclusion scheme that the LCCP requires online gambling licensees, with some exceptions for ancillary and business-to-business licence types, to join (social responsibility code 3.5.5). The Commission tracks affiliate pages that use terms such as "not on GAMSTOP" to target people who have self-excluded when it measures the unlicensed market. Such pages exist to send self-excluded people to unlicensed operators. They risk the offence of advertising unlawful gambling under section 330 of the Gambling Act 2005, they target the most vulnerable audience the industry has, and a licensed operator found to be working with an affiliate that runs one can be expected to terminate the affiliate at once. An affiliate with any ambition to work with British-licensed operators does not publish them, and the search-ranking operations that do are the affiliate industry's black market.

The 2023 White Paper and after

The reforms in progress since the White Paper of April 2023 reach affiliates in several places. Bonus and promotion rules restrict the structure of offers: since 19 January 2026 bonus wagering requirements have been capped at ten times and a single promotion may not mix products such as betting and casino, which narrows what an affiliate can promote and requires existing content to be updated. Direct marketing consent rules in force since 1 May 2025 require online operators to let customers opt in by product and by channel; an affiliate emailing on an operator's behalf must respect those choices, as well as the consent its own email marketing already needs. The stake limits and game design rules change what game content may show: online slots stakes have been capped at £5 since 9 April 2025, and at £2 for 18 to 24 year olds since 21 May 2025, and since 17 January 2025 the design rules for slots, such as the bans on autoplay and turbo features, have been extended to other online casino games. Separately, the government consulted from 15 July to 9 September 2026 on banning sponsorship and advertising by gambling operators not licensed by the Commission, with a preferred start date of August 2027 and a scope covering sport and every other sector. The proposal covers physical advertising only, because extending it online would need primary legislation, so the affiliate and social channels through which unlicensed brands reach British customers remain a matter for the Commission's illegal-market work. The UK Gambling Regulation Explained guide sets out the wider programme.

What the Commission has said about affiliates directly

Beyond the conditions, the Commission has published guidance and made statements that affiliates should read as instructions. It has told licensees to monitor their business relationships and end them where partners take part in offering illegal gambling to British consumers, noting that illegal sites often target people who have self-excluded through GAMSTOP; an affiliate that also promotes unlicensed operators to British customers puts the operator paying it on the wrong side of that expectation. Its licence conditions require operators to bind affiliates by contract to act as if subject to the operator's own conditions and codes, so affiliate marketing must meet the same standard as the operator's own. It has told operators to apply the codes' principles to social media content even where the ASA's remit does not reach, and the ASA has ruled against gambling social content on strong-appeal grounds. And its illegal-market team issues cease-and-desist notices to advertisers and affiliates and refers sites to hosting providers, registrars and search engines: its report on that work, first published in October 2025, says it has referred 447,778 URLs to Google and Bing since April 2024.

What a British-facing affiliate does

An affiliate that wants to be paid by British-licensed operators runs a British compliance process regardless of where it is based:

A page template carrying the 18-plus statement, safer-gambling messaging and disclosure automatically.

A bonus and terms database that renders significant conditions with every offer and removes offers when they end.

An approval workflow that sends new and changed pages to the operator where the agreement requires it, and records the approval.

A prohibited-content list that excludes self-exclusion circumvention, unlicensed operators, guaranteed-win claims and strong-appeal imagery.

A record of every operator relationship and every sub-affiliate, available on request.

Monitoring of its own pages and channels against the codes, with a log of findings and fixes, because that log is what an operator's audit asks for.

A British-facing affiliate that only markets, rather than providing facilities for gambling, does not need a licence from the Commission. It needs to behave as though the Commission could read any page tomorrow, because the operator paying it has to assume exactly that.

What to take from this lesson

Britain regulates affiliates through the operator's licence: contract, approve, monitor, identify, terminate. The CAP Code's gambling rules apply to affiliate content directly, above all significant conditions with every offer, no strong appeal to children, no irresponsible messaging and disclosure of the commercial relationship. Self-exclusion circumvention pages are the industry's black market and end relationships instantly. The White Paper reforms narrow what can be promoted and how, and the Commission has told operators to end relationships with partners that take part in unlicensed gambling aimed at British customers.

Key terms

LCCP
The Gambling Commission's Licence Conditions and Codes of Practice, which make operators responsible for third-party marketing done on their behalf.
CAP Code
The UK non-broadcast advertising code administered by the ASA, whose gambling section applies to affiliate websites, social and email.
Significant conditions
The terms that must accompany an offer clearly and prominently in the ad itself under CAP rule 8.17: eligibility, deposit or wagering requirements, time limits and restrictions on qualifying bets or games, with full terms usually one click away.
Strong appeal
The test in CAP rule 16.3.12, in force since 1 October 2022, for content likely to appeal strongly to under-18s, which rules out topflight footballers, sportspeople and influencers popular with under-18s and youth-culture imagery in gambling advertising.
GAMSTOP
Britain's national online self-exclusion scheme. Pages built to route excluded people around it are the worst affiliate conduct in the market.

Key takeaways

  • "We told the affiliate the rules" is not compliance; "we checked, found the breach and acted" is.
  • A bonus shown without its significant conditions is likely to breach CAP rule 8.17, and the ASA holds the operator responsible for its affiliates' pages.
  • The strong-appeal test restricts sports personalities, characters and youth-appeal imagery, and the ASA has applied it to gambling operators' social media posts.
  • "Casinos not on GAMSTOP" pages risk the offence of advertising unlawful gambling, target the most vulnerable audience and are the affiliate industry's black market.
  • A British-facing affiliate behaves as though the Commission could read any page tomorrow, because the operator paying it must assume exactly that.

Sources

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

  1. Licence Conditions and Codes of Practice (codes 1.1.2, 3.5.5, 5.1.1, 5.1.6, 5.1.8, 5.1.9, 5.1.12), Gambling Commission, accessed 2026-09-23
  2. Licensees responsibilities for third parties, Gambling Commission, accessed 2026-09-23
  3. Affiliates or third parties: ensuring self-excluded customers do not receive marketing, Gambling Commission, accessed 2026-09-23
  4. Key events: reporting incidents, Gambling Commission, accessed 2026-09-23
  5. Gambling on your affiliates?, Advertising Standards Authority / CAP, accessed 2026-09-23
  6. CAP Code section 16: Gambling, Advertising Standards Authority / CAP, accessed 2026-09-23
  7. CAP Code section 2: Recognition of marketing communications, Advertising Standards Authority / CAP, accessed 2026-09-23
  8. CAP Code section 3: Misleading advertising, Advertising Standards Authority / CAP, accessed 2026-09-23
  9. Gambling, betting and gaming: free bets and bonuses, Advertising Standards Authority / CAP, accessed 2026-09-23
  10. Tough new rules to curb broad appeal of gambling ads and better protect under-18s, Advertising Standards Authority / CAP, accessed 2026-09-23
  11. The odds are... it's an ad! Gambling 'content marketing' and the Code, Advertising Standards Authority / CAP, accessed 2026-09-23
  12. Gambling advertising: responsibility and problem gambling (advertising guidance), Committee of Advertising Practice, accessed 2026-09-23
  13. Gambling Industry Code for Socially Responsible Advertising, 7th edition (updated February 2026), Betting and Gaming Council / Industry Group for Responsible Gambling, accessed 2026-09-23
  14. Gambling Act 2005, section 330: Unlawful gambling (advertising), legislation.gov.uk, accessed 2026-09-23
  15. Gambling Act 2005, section 33: Provision of facilities for gambling, legislation.gov.uk, accessed 2026-09-23
  16. Unlicensed gambling: using data to identify unlicensed operators and estimate the scale of this market (October 2024), Gambling Commission, accessed 2026-09-23
  17. High stakes: gambling reform for the digital age, Department for Culture, Media and Sport, accessed 2026-09-23
  18. Gambling promotions to be safer and simpler, Gambling Commission, accessed 2026-09-23
  19. New rules boosting safety and consumer choice, Gambling Commission, accessed 2026-09-23
  20. Online slots stake limit guidance, Gambling Commission, accessed 2026-09-23
  21. Consultation on banning unlicensed gambling sponsorship, Department for Culture, Media and Sport, accessed 2026-09-23
  22. Industry warning notice: licensed software appearing on illegal market, Gambling Commission, accessed 2026-09-23
  23. Illegal online gambling: disruption of illegal online gambling, summary of disruption activity, Gambling Commission, accessed 2026-09-23

Check your understanding

4 questions · answer them all, then check.

  1. 1. What does the Commission expect an operator to be able to show about its affiliates?

  2. 2. An affiliate page shows "100 free spins" with the wagering requirement in the footer. What is the problem?

  3. 3. What happens to an affiliate found running a "not on GAMSTOP" page?

  4. 4. Which White Paper reform reaches an affiliate's own email marketing?

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