As Finland continues to refine the details of its gambling framework ahead of the 2026 launch, stakeholders are expressing concerns over the current approach to affiliates and digital marketing.
The mechanisms of the new legislation will be implemented throughout the year leading up to the commercial market launch in July 2027. Licenses for sports betting and online casinos will start being issued in March, while Lotto, Eurojackpot, and gaming terminals will remain under the control of the state-owned operator Veikkaus.
Final decisions on several key aspects of the legislation will be made before the market goes live. However, warnings have already been raised that the current approach to marketing regulation could significantly impact the profitability of smaller operators.
Digital Direction
Jari Vähänen, Co-Founder and Partner at The Finnish Gambling Consultants, notes that marketing regulations remain unclear at present and require greater focus on the digital sphere.
“The legislation approved in December remains imprecise regarding marketing, so it isn’t easy to assess the marketing opportunities in the future license-based market for now,” noted Vähänen.
“According to my interpretation, large operators with sufficient funds to participate in ‘brand advertising competitions’ in mass media will have good business opportunities. On the other hand, the upcoming restrictions on digital marketing will pose challenges for smaller operators. Therefore, there is a risk that several companies will continue to operate in the black market.
“I would have liked to allow licensed companies to compete with modern digital marketing tools and would have preferred to limit mass media marketing, because it targets everyone, not just customers interested in gambling.”
Antti Koivula, Chief Compliance Officer at Hippos ATG, agrees with Vähänen that restrictions on digital marketing could create serious challenges for Finland’s new licensed commercial market.
“My concern is that the new rules are fairly permissive for traditional mass media and sponsorships, but very strict for digital marketing. This creates two big problems.
“First, it pushes more marketing into mass media that people cannot really avoid, including minors and vulnerable groups. If the goal is to reduce harmful exposure, the logic should be the other way around: stricter limits on mass media, and a controlled but workable space for targeted, age-gated digital marketing.
“Second, digital marketing will not go away by prohibiting it. Affiliates, influencers, social media and other digital marketing channels will still exist. If licensed operators cannot use these channels, unlicensed operators will.
“Expecting these channels to stop targeting Finland is unrealistic unless enforcement becomes very strong, including across borders. And right now, that does not look likely. If legal operators cannot compete where people actually discover brands, channelisation will drop, and all the negative effects will follow.
“Overall, I am extremely worried that the current choices will do the opposite of what the reform is meant to achieve: they will help the black market, increase harm, and reduce channelisation.”
Marketing Must Be Responsible
Last month, Finland’s gambling bill received bipartisan parliamentary support, with 158 votes in favor and 9 against. The bill proposes a transition from Veikkaus monopoly to a licensed and regulated market. The law only requires the President’s signature to come into effect.
Finland’s National Police Board will make licensing decisions before the Licensing and Supervision Agency takes over regulatory responsibilities in June. The B2B licensing process will begin in July next year, and by July 2028, a license will be required to operate on the market.
Koivula urged Finland to completely rethink its current marketing strategy.
“The starting point is simple: licensed operators must be allowed to market enough so people can find them, compare them and choose them,” stated Koivula.
“If legal operators cannot be seen, demand will not disappear. It will move to the black market. That means less consumer protection, more harm and less tax income for the state.
“At the same time, marketing must be responsible. Finland should not repeat the trend we have already seen under the monopoly system, where gambling harms have grown rapidly. Minors and other vulnerable people must be protected. That requires clear and consistent rules that push marketing into places where exposure can be limited and checked.”
Affiliates Could Continue Operating on the Black Market
Vähänen warns that restrictions on affiliate marketing will not stop promotions via the black market.
“I believe the Finnish media will not accept advertising from black-market operators. At least this has been the case so far. Instead, I am terrified that affiliates will continue to operate, and black market operators will be their only customers, because licensed companies are not allowed to use affiliates.
“The success of the entire gambling system will depend on how the new regulator is able to prevent the business of companies operating without a Finnish license. Unfortunately, I am sceptical about this, but I hope I am wrong.”
Vähänen added that casino operators will be impacted by the ban on affiliate marketing, stating that 50% to 90% of customers are acquired through that channel. Other restrictions will affect operations as well.
“A considerable means is the use of welcome bonuses, which will also be prohibited under the new Finnish system. I assume that the current affiliates that attract Finnish customers will continue their operations and, in particular, direct Finnish casino customers to black market operators.
“This will probably not be as big a problem in the betting business. Influencers are a subcategory of affiliates. I myself would have been ready to ban influencers, but I would have liked to allow, for example, betting and, why not, casino comparison sites.”
The Year Ahead
Several questions still need refinement and clarification, including secondary legislation, which will define game characteristics (autoplay, bonus buys), maximum stakes, and game speed; technical regulations; and guidance on key interpretative issues, particularly in marketing.
Exact timelines for the publication of these changes remain unclear, as Finland’s Parliament will not reconvene until next month. Presidential and vice-presidential elections are scheduled for February 3, the opening of the 2026 parliament on February 4, and an oral question-and-answer session on February 5.
2026 is set to be a crucial year for Finland’s gambling industry. The question arises: what marketing direction should be set for the European market when commercial operators go live in July 2027?
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