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Lesson 6 of 7 · 16 min

Markets, Licences and Unlicensed Competition

Advertising rules apply to organic pages; the rules that shape them; the three market positions; four responses to unlicensed competitors; and preparing for a market that regulates.

Fact-checked 23 September 2026 by iGaming Times editorial team · 25 sources

In this lesson

  • Explain why compliance is a column in the keyword map and belongs in the page template
  • List the recurring rules that constrain gambling pages: offers, audience, claims, mandatory information, affiliates
  • Distinguish licensed-only, licensed-plus-grey and global positions and their consequences
  • Apply the four responses to unlicensed competition and prepare for a regulating market

The regulator reads organic pages too

In most licensed markets, the rules on gambling advertising apply to any commercial communication, and a promotional page that ranks in search is one. The bonus term that must appear with its conditions, the age statement, the responsible gambling message, the prohibition on appealing to minors or presenting gambling as a solution to financial problems: all of it applies to a landing page found through search exactly as it applies to a television advert. Britain's advertising code, for example, covers marketing on a company's own website, though not the natural search listing itself. Regulators have fined operators for promotions on their own websites and on the affiliate pages promoting them: the Gambling Commission's first financial penalty for advertising failings, in 2017, was a £300,000 fine on BGO Entertainment for misleading advertising on its own and its affiliates' websites.

That makes compliance a part of SEO in a way it is in no other industry. A page cannot be optimised for a term without being checked against the rules of every market in which it will be shown, and the map from lesson two needs a column the keyword tools do not provide: what may be said about this term, to this audience, here.

The rules that shape pages

The detail differs by market and changes often, but the recurring rules that constrain gambling pages are the same few.

Offers. Significant conditions with the offer: in Britain they must be clearly stated in the initial promotional material and, on a promoter's own website, set out upfront rather than hidden at the bottom of a long page. Several markets restrict offers well beyond disclosure. Sweden allows a licensee to offer a bonus only on the first occasion a player plays, which rules out recurring reload and free spins promotions there; Ontario prohibits advertising bonuses anywhere except on the operator's own gaming site and in direct marketing the player has consented to, and bars calling an offer "risk-free" if the player must risk their own money. A page built around a prohibited offer is a page that cannot exist in that market.

Audience. No content that appeals particularly to under-18s (in Britain, nothing likely to be of strong appeal to children or young persons) or, where the legal age is 21, to under-21s, which affects imagery, tone and, in some markets, the use of sports personalities or characters: Ontario bars active or retired athletes from gambling advertising except to promote responsible gambling. No targeting of self-excluded or vulnerable people, which is why the circumvention terms in lesson two are off limits.

Claims. No suggestion that gambling is a solution to financial concerns, an escape from personal problems or a way to enhance personal qualities; nothing that presents winning as the probable outcome or implies that chances improve the longer a player plays or the more they spend. This rules out a large share of what ranks for "how to win" terms.

Mandatory information. Age warnings, responsible gambling messages, helpline details and licence information, in the form each market prescribes. Some markets require them in commercial messages, as Sweden does for the minimum age and, except on radio, a problem-gambling helpline; some prescribe the message, as Spain does with a required responsible-play message along the lines of "si juegas, juega con responsabilidad"; and Sweden also requires responsible-gambling logos in a locked bar at the top of every licensed site and app, visible even when the player scrolls.

Affiliates. In several markets affiliates must be licensed or registered: Pennsylvania certifies affiliates paid a revenue share and registers those paid a flat fee. Elsewhere, as in Britain, licensees are responsible for the third parties they contract with and must be able to terminate an affiliate that breaches an advertising code, and the gambling advertising rules apply to affiliate marketers acting on an advertiser's behalf. An affiliate page that breaks the rules is the operator's breach.

A gambling site's compliance function should sign off page templates, not individual pages, and the SEO team should build templates that carry the mandatory elements automatically, market by market, so that a new page is compliant by default. Sites that rely on a person remembering the age warning are the ones that end up in breach.

Geo-targeting and the licence map

A page that ranks globally reaches customers in markets where the business is not licensed, and in many of those markets serving them is illegal. The technical answer, from lesson three, is market-specific pages with hreflang and blocking applied to the user rather than the crawler. The strategic answer is to decide which markets the site competes in at all.

Three positions exist. Licensed markets only: content and rankings pursued only where the business holds a licence, with other markets blocked and no content targeting them. This is what regulators expect and what licensed operators do. Licensed plus grey: content targeting markets that have no licensing regime and do not prohibit offshore play, which is a legal grey area some of the sector's larger operators have left: Entain, for example, committed in 2020 to taking all its revenue from nationally regulated markets and in 2023 accelerated its exit from unregulated markets with no path to regulation. Global: the unlicensed model, in which a site targets every market and blocks nothing. Organic search results do not currently distinguish the three; regulators do, and so, increasingly, do the payment providers, advertising platforms and app stores whose policies reference a business's licensing. Google allows gambling ads only in listed countries and only from certified advertisers that meet each country's licensing requirement, and Apple requires real-money gaming apps to hold the necessary licensing where they are used and to be geo-restricted to those locations.

Competing with unlicensed sites

The top organic result for a market's highest-volume term is, in many markets, a site that cannot legally serve customers there. Unlicensed operators and their affiliates rank with content that breaks every rule above, target the circumvention terms licensed sites cannot touch, buy the links licensed sites will not, and have no compliance function to slow them down. A licensed operator's SEO team spends a great deal of time explaining this to its board.

Four responses exist and are used together.

Report. Search engines accept reports of spam and of content that violates their policies: Google takes search quality user reports of spam and requests to remove content that breaks the law. National regulators in a growing list of markets act against the sites directly. In Australia the ACMA asks internet service providers to block illegal gambling websites and publishes the list; Belgium's Gaming Commission publishes the list of illegal gambling sites it has had blocked; in the Netherlands the Kansspelautoriteit issued a binding instruction in 2024 to a hosting provider serving two sites that advertised illegal gambling, withdrawn in July 2024 once it emerged the host had already stopped serving them, and it works with Google, Meta, app stores, banks and the licensed industry's trade bodies against illegal offers. Licensed operators contribute to those efforts through their trade bodies.

Out-trust. Where an unlicensed site ranks through purchased links and thin content, a licensed site that carries the trust signals from lesson four is competing on the dimension the search engine is trying to reward. This is slow, but unlike the other side's tactics it does not depend on the search engine failing to notice them.

Own the brand. Unlicensed affiliates rank for licensed operators' brand terms with review pages that route the visitor elsewhere. An operator that owns every variant of its own name, including "bonus", "review", "login" and "app", takes that traffic back.

Take the question terms. Unlicensed sites rarely invest in genuine informational content. A licensed site that owns "is online gambling legal in X", "how do I know if a casino is licensed" and "how to check a licence" is where a cautious customer starts, and it can direct them to the licensed market.

When the market changes

Markets regulate, and when they do, the search landscape resets. A newly licensed market's regulator publishes advertising rules, the search engines begin accepting certification for paid search (Google's gambling ads policy now lists Brazil, where certified advertisers must be licensed by the Brazilian authorities), and the grey-market affiliates that ranked for years either move to licensed brands or lose their operator relationships, because regulators such as Ontario's bar operators from paying affiliates that also promote unregistered sites. Brazil, where only operators authorised by the Secretaria de Prêmios e Apostas could operate nationally from 1 January 2025 until fixed-odds betting was prohibited in September 2026, and several US states before it show the pattern: the operators ready with compliant, market-specific pages on day one were placed to take the organic positions that the pre-regulation sites vacated.

Preparation for a regulating market is a keyword map in the local language, a compliant page template built to the new rules as soon as they are published, and reference content (what the new law says, how to check a licence, what changes for players) that ranks before the commercial terms are contestable.

Language and the local engine

Google is not the only search engine that matters. Yandex leads in Russia and Baidu in China, Naver runs close to Google in South Korea and Seznam keeps a significant share in the Czech Republic: for August 2026, StatCounter measured Yandex at 70% in Russia, Baidu at 59% in China, Naver at 44% against Google's 47% in South Korea and Seznam at 16% in the Czech Republic. Each applies its own content and advertising policies, and the gambling law of the market it serves applies on top. A site expanding into a market should know which engine its customers use and what that engine permits before building anything.

What to take from this lesson

Advertising rules apply to organic pages, so compliance is part of the keyword map and belongs in the page template. Decide which markets the site competes in and build the technical structure to match. Unlicensed competitors rank by breaking the rules; the answers are reporting them, out-trusting them, owning the brand terms they take and the question terms they ignore. When a market regulates, the sites that prepared take the positions the grey market leaves.

Key terms

Significant conditions
The terms that must accompany an offer (for a gambling bonus: wagering, expiry, maximum win, eligible games), stated clearly in the initial promotional material rather than hidden behind a link. The term comes from the UK CAP Code (rule 8.17); licensed markets such as Ontario have equivalent disclosure rules.
Compliant template
A page template that carries a market's mandatory elements (age warning, helpline, licence, responsible gambling message) automatically, so a new page is compliant by default.
Grey market
A jurisdiction with no licensing regime that does not prohibit offshore play. Some larger operators, such as Entain, have committed to leaving unregulated markets that show no path to regulation.
Delisting
Removal of an unlicensed site from search results following a legal request, often alongside blocking of its domain by internet service providers. Regulators such as Australia's ACMA and Belgium's Gaming Commission publish lists of the gambling sites they have had blocked.
Day-one readiness
A local-language keyword map, a compliant template built to the new rules and reference content ranking before commercial terms are contestable, prepared ahead of a market's regulation.

Key takeaways

  • A promotional page that ranks in search is a commercial communication; regulators have fined operators for promotions on their own websites and on affiliate pages promoting them.
  • Compliance should sign off page templates that carry mandatory elements automatically, market by market; sites that rely on a person remembering the age warning end up in breach.
  • Search engines do not currently distinguish licensed, grey and global positions; regulators, payment providers, ad platforms and app stores increasingly do.
  • Against unlicensed competitors: report, out-trust, own the brand terms they take, own the question terms they ignore.
  • When a market regulates, the operators with compliant, market-specific pages ready on day one are placed to take the positions the grey market vacates.

Sources

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

  1. UK Code of Non-broadcast Advertising (CAP Code): scope of the Code, Advertising Standards Authority / CAP, accessed 2026-09-23
  2. CAP Code, section 16: Gambling (rules 16.3.3, 16.3.4, 16.3.6 and 16.3.12), Advertising Standards Authority / CAP, accessed 2026-09-23
  3. Promotional marketing: terms and conditions and significant conditions (AdviceOnline), Advertising Standards Authority / CAP, accessed 2026-09-23
  4. Gambling business fined £300,000 for misleading advertising (BGO Entertainment, 2 May 2017), Gambling Commission, accessed 2026-09-23
  5. Licence Conditions and Codes of Practice, social responsibility code 1.1.2: Responsibility for third parties, Gambling Commission, accessed 2026-09-23
  6. Registrar's Standards for Internet Gaming, Standards 1.21, 2.03, 2.04, 2.05 and 2.06, Alcohol and Gaming Commission of Ontario, accessed 2026-09-23
  7. 58 Pa. Code § 807a.1, general interactive gaming service provider requirements, Pennsylvania Code and Bulletin, accessed 2026-09-23
  8. Spellag (2018:1138), 14 kap. 9 § (bonus) and 15 kap. 3 § (information in commercial messages), Sveriges riksdag, accessed 2026-09-23
  9. Logotyper för spelansvar (responsible-gambling logos), Spelinspektionen, accessed 2026-09-23
  10. Real Decreto 958/2020, de comunicaciones comerciales de las actividades de juego (consolidated text), article 10.3, Boletín Oficial del Estado, accessed 2026-09-23
  11. Apostas de Quota Fixa, Ministério da Fazenda, Secretaria de Prêmios e Apostas, accessed 2026-09-23
  12. Blocked gambling websites, Australian Communications and Media Authority, accessed 2026-09-23
  13. List of illegal gambling sites blocked by the GC, Belgian Gaming Commission, accessed 2026-09-23
  14. Bindende aanwijzing DigitalOcean ingetrokken, Kansspelautoriteit, accessed 2026-09-23
  15. Aanpak illegale online gokspelen, Kansspelautoriteit, accessed 2026-09-23
  16. Acceleration of unregulated market exits (18 January 2023), Entain plc, accessed 2026-09-23
  17. Gambling and games policy, Google Ads, accessed 2026-09-23
  18. App Review Guidelines, 5.3 Gaming, Gambling, and Lotteries, Apple, accessed 2026-09-23
  19. Spam policies for Google web search, Google Search Central, accessed 2026-09-23
  20. Report content for legal reasons, Google Legal Help, accessed 2026-09-23
  21. Search engine market share, Russian Federation (August 2026), StatCounter Global Stats, accessed 2026-09-23
  22. Search engine market share, China (August 2026), StatCounter Global Stats, accessed 2026-09-23
  23. Search engine market share, South Korea (August 2026), StatCounter Global Stats, accessed 2026-09-23
  24. Search engine market share, Czech Republic (August 2026), StatCounter Global Stats, accessed 2026-09-23
  25. 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. A ranking landing page shows a bonus without its wagering requirement. What kind of problem is this?

  2. 2. How should mandatory elements like age warnings and helplines be handled on a large gambling site?

  3. 3. Which response to unlicensed competition has worked over multiple updates?

  4. 4. What happened to organic positions in markets that regulated, such as Brazil in 2025?

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