Affiliate Compliance Report
Standing section, revised August 2026
Section 1
The foundational rule of affiliate compliance in regulated iGaming is that the licence holder is responsible for advertising carried out on its behalf. An affiliate is not a licensed entity in most markets, so the regulator has no direct hold over it. The regulator instead holds the operator to account for what the affiliate publishes. This principle appears in materially identical form in the licence conditions of Great Britain, the marketing regulations of Sweden and Denmark, the advertising decrees of the Netherlands, and the state rules of regulated US markets.
The practical consequence is that an operator cannot outsource compliance by contract. An indemnity clause shifts money after the fact. It does not shift the fine, the licence review or the public enforcement notice.
Section 2
| Market type | Affiliate registration | Operator duty |
|---|---|---|
| Locally licensed, strict (SE, DK, NL) | Not licensed, operator vouches | Full liability for affiliate content and targeting |
| Locally licensed, mature (GB) | Not licensed | Liability plus documented affiliate oversight expected |
| US state markets (NJ, MI, PA) | Affiliate registration or vendor licence required | Shared duty, both parties exposed |
| Offshore licences (Curacao, Anjouan) | None | Contractual only, reputational in practice |
Section 3
| Control | What it covers | Common failure |
|---|---|---|
| Written terms | Prohibited claims, brand bidding ban, jurisdiction list | Terms exist but are never enforced |
| Onboarding review | Identity, traffic sources, sample content | Approval based on projected volume alone |
| Content approval | Bonus wording, terms display, age and safer gambling messaging | Approval given once, content changes later |
| Ongoing monitoring | Live checks of what affiliates actually publish | Nobody owns the task |
| Termination path | Warning, withholding, removal from program | Revenue keeps violators inside the program |
The pattern across enforcement actions since 2023 is consistent. Regulators rarely fault an operator for lacking rules. They fault the operator for holding rules it demonstrably did not police. A short, enforced term sheet beats a long, ignored one in every published case this report has reviewed.
Records matter as much as rules. When a regulator asks about a violating affiliate, the operator that produces onboarding checks, approval logs and a dated termination trail is treated differently from the operator that produces a contract and silence. Affiliate compliance at the baseline level is record keeping with consequences attached, and the two sections that follow cover the places where those records most often turn out to be empty.