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Finnish gambling stakeholders worry that the country's revamped market will not be able to maintain strong channelisation if the government implements a ban on traditional affiliate marketing.
Under the terms of Finland’s new draft gambling law, affiliate marketing would be broadly outlawed and traditional marketing models based on revenue sharing would not be allowed.
Finland’s licensed gambling market is set to start in July 2026, bringing to an end the monopoly model that means state-owned Veikkaus is the only operator in the market.
Mika Kuismanen, the CEO of the Finnish Trade Association for Online Gambling, said he thought channelisation rates would rise to above 80 percent in the first few months of the new market.
“But then we will most likely see a phenomenon like we have seen in Sweden, so it will gradually decrease from there,” he said, speaking at the Scandinavian & Nordic Gaming Show on Wednesday (November 6).
Kuismanen pointed to the lack of affiliate marketing and restrictions on bonuses as key reasons why Finns may be tempted back to the black market.
Only retention bonuses will be permitted, according to the latest draft, and even then limited by strict parameters designed to limit operators’ ability to entice players to gamble more.
Several sources indicated to Vixio that the prohibitions on affiliates and bonuses were unlikely to change during upcoming parliamentary discussions and that explanatory notes published alongside the new draft on November 1 made it clear that preventing traditional affiliate marketing is the government’s express desire.
“The biggest losers [of the new regime] are compliant affiliates in Finland,” said Esko Rissanen, the CEO of affiliate Traffic Lab.
By contrast, affiliates willing to ignore the licensed market and direct players offshore will thrive, he said.
The fear that Google search results will be populated by websites run by black market-facing affiliates is at the core of concerns that Finland will struggle to effectively channel its players to licensed operators.
“I personally don’t think it’s going to be a success. I think channelisation will go up in the beginning, but then it will rapidly come down,” said Rissanen.
Others had a less gloomy view of the future of affiliates in Finland.
“I think that the affiliates will find new means of getting into the picture. So in that sense, this is not doomsday for affiliates,” said Pia Ek, a partner at Bird & Bird in Helsinki.
Finnish legal experts noted that the Finnish draft law does not explicitly rule out all kinds of affiliate marketing. Websites that operate as sources of information or news might be able to run gambling ads, albeit not on the usual pay-per-player model currently favoured by affiliates.
Beyond these limits, industry figures appeared broadly happy with the draft in its current state.
“I think we should give credit to the current government,” said Kuismanen.
However, the assembled experts were less confident that the government could hit its recently accelerated timeline to open the market by July 1, 2026.
Most expect a delay of at least a few months, with some predicting that the deadline will slip back to the originally planned date of January 1, 2027.
One wrinkle of the incoming Finnish system which may work to limit the black market is a player winnings tax.
Once the new regime is in place, Finns gambling within the licensed system will not pay taxes on their winnings.
However, anyone gambling with offshore operators would be taxed on their winnings, not including any losses, potentially costing players more than their net winnings.
