Regulatory Changes Affiliates Should Watch Through 2027
Sourced, dated developments in Finland, the Netherlands, Sweden and Germany, and which ones are already rules versus which are still proposals.

Three published rules and one regulator analysis worth tracking, each with a primary source and a date. None of this is speculation about where regulation might go — but not every item here is already in force, and the piece says plainly which is which. Check each source directly before relying on a summary, including this one, and treat this list as a starting point for your own reading rather than a substitute for it.
Finland: affiliate marketing prohibited outright from 1 July 2027
Finland's new Gambling Act — Rahapelilaki 10/2026 in the country's own statute register, analysed in a practical guide published by law firm Borenius on 28 May 2026 — restricts licensed operators to a specific, closed list of marketing channels once the Act enters into force: the operator's own website and social accounts, television and radio, sports and public event sponsorship, print media, gaming premises, and search-engine advertising bought against the operator's own brand terms. Affiliate and influencer marketing are not on that list, and Borenius's guide states the prohibition explicitly: "Marketing through any channel not expressly listed, including affiliate and influencer marketing, is prohibited." The Act takes effect on 1 July 2027, the same date licensed gambling operations in the newly competitive Finnish market can begin. For any affiliate with Finnish-language content or Finnish traffic, this is the single most consequential date on this list — it is a market that, as things stand, an affiliate promoting a licensed operator will not legally be able to serve through a commission-based link after that date.
Netherlands: new guidance on the untargeted-advertising rule, 18 March 2026
The Dutch gambling regulator, the Kansspelautoriteit, has enforced a ban on untargeted gambling advertising since 1 July 2023, and on 18 March 2026 it published new guidance (leidraad) clarifying how licence holders must apply the rule in practice — including how advertising placed through external platforms and third parties has to be documented and how a genuine, working opt-out has to be offered to be considered compliant. The guidance does not change who the rule targets — it is addressed to licence holders, not directly to affiliates — but it tightens exactly the kind of arrangement an affiliate relationship sits inside: an operator is expected to be able to show how a third party's advertising placement met the targeting conditions, which is a documentation burden that flows downstream to whoever the operator is paying to place that content.
Sweden: the regulator's own analysis names affiliate networks as a channel, 10 June 2026
This one is an analysis, not yet a rule, and is worth reading as a signal rather than a settled change. Spelinspektionen, the Swedish gambling authority, published an in-depth report, "Marknadsföring för olicensierat spel" (marketing for unlicensed gambling), dated 10 June 2026, with an entire section — "2.1 Affiliateverksamhet" — devoted to affiliate networks and affiliate websites as a channel unlicensed operators use to reach Swedish players: the report says that searches for phrases like "casinon utan svensk licens" lead to hundreds of affiliate websites for unlicensed gambling, which sometimes link between each other in complex chains across Swedish- and English-language sites until some of those links finally reach unlicensed operators. It gives two explanations for the arrangement and picks neither: it "kan vara" a way for affiliate networks to avoid and obstruct the supervisory authorities, "men kan också vara" a way of manipulating search-engine indexing so the sites are treated as more relevant. The authority's second-quarter update, published 20 July 2026, summarises that analysis and separately lists the broader marketing channels it tracks — social media, influencers, banners, SMS and sponsored search results — while noting that oversight of licensed operators' own marketing sits with a different agency, the Swedish Consumer Agency (Konsumentverket), not Spelinspektionen. Neither document proposes a new, affiliate-specific rule; the analysis instead references a separate government memorandum, Ds 2025:23, which proposes replacing the law's current "targeting" test for what counts as gambling aimed at Sweden with a "participation" test, intended to take effect 1 January 2027 — a jurisdictional change aimed at unlicensed sites generally, not affiliates specifically, though it would remove one of the arguments an affiliate-driven unlicensed operator currently has for arguing Swedish rules do not apply to it. What is already true, independent of whether that memo becomes law, is that the country's own regulator now names affiliate networks and affiliate websites directly, by name, as a channel it watches.
Germany: an operator answers for its commissioned third parties, confirmed 13 February 2025
Germany's Gemeinsame Glücksspielbehörde der Länder (GGL) reported a win at the Bundesverwaltungsgericht (Federal Administrative Court) in a press release dated 13 February 2025 — note the release itself states the court's written reasons had not yet been published at that point, so what follows is the regulator's own characterisation of the outcome, not a quote from the judgment. The case concerned a social-lottery operator's licence, and the obligation the court upheld was an ancillary condition attached to that licence: the operator must ensure that "beauftragte Dritte" — third parties it commissions — comply with the advertising rules that bind the operator itself. It is not, on its face, a ruling about commercial sportsbook or casino advertising, but the principle it confirms applies with the same logic there: a licence holder cannot point at whoever it paid to run a campaign as the party responsible for a violation. An affiliate publishing non-compliant creative on an operator's behalf does not shield the operator, and an operator that takes this seriously pushes compliance requirements down into its affiliate contracts and creative-approval processes rather than leaving them unstated.
The pattern across all four
Read together, these four items point the same direction even though they come from four different regulators at four different stages: Finland removes affiliate marketing from the picture entirely for its own market, by statute, effective 2027; the Netherlands and Germany both already hold licence holders accountable for the advertising a third party places on their behalf, tightening the documentation that accountability requires; and Sweden's own regulator has, for the first time this explicitly, named affiliate networks and affiliate websites as a channel it studies, without yet proposing a rule aimed at them specifically. None of this means the affiliate model is ending — it means the paperwork and the market-by-market attention it requires is going up, and an affiliate who tracks licence-and-marketing rules per market, the way this site's compliance guide for the UK, Germany, Sweden and Spain sets out, is the one who is not surprised by any of these dates when they arrive. This site also carries an earlier, broader survey of the same four markets — affiliate regulation watch 2026 — worth reading alongside this piece rather than instead of it.
Notice, too, that three of these four developments are from 2026: the Netherlands' guidance (18 March 2026), Sweden's analysis (10 June 2026) and its quarterly update (20 July 2026), and Finland's Act, analysed 28 May 2026, all landed within five months of each other. Only the German case, from February 2025, is older — and its "an operator answers for whoever it commissions" principle is exactly the standing law the newer, faster-moving rules in the other three markets are being built on top of. Licence jurisdiction rules are moving quickly right now, and a market that looks settled today is not a guarantee it stays that way through 2027.
What we would do this week
- If any of your traffic or content targets Finland, read the Rahapelilaki text or the Borenius analysis in full and start planning for a market where affiliate promotion of licensed gambling operators is legally closed from 1 July 2027.
- If you promote operators licensed in the Netherlands or Germany, check the current creative-approval and disclosure requirements in your program contract — both markets already hold the operator accountable for an affiliate's advertising.
- Bookmark each regulator's own news page rather than relying on secondary summaries — the program directory lists the licences each program states, as a starting point for which regulators actually apply to your content.