Do Gambling Affiliates Need a Licence? The 2026 Country Map

Most gambling affiliates do not need a licence. In the UK, Malta, Ontario, Brazil and the bulk of regulated markets, the operator carries the regulatory liability for its affiliates. But “most” is carrying a lot of weight. Romania sells a real affiliate licence at roughly €35,000 a year, Greece runs a licence-plus-registry system, Gibraltar made marketing services licensable on 1 October 2025, about a dozen US states licence revenue-share affiliates, and Finland and New Zealand banned affiliate marketing outright. Here is the 2026 map, country by country.

The four buckets

Every jurisdiction we track in the Affiliate Licensing Index fits one of four buckets:

1. Formal licence or registration. The regulator licenses, registers or pre-approves the affiliate itself.
2. Bans. Affiliate marketing is prohibited, either outright or by banning the compensation that makes it work.
3. Advertising pre-approval. No affiliate licence, but every piece of gambling advertising needs the regulator’s sign-off before it runs.
4. Operator liability. The affiliate holds no paper; the operator answers for everything the affiliate publishes.

Which bucket you are in decides whether you are filing an application, restructuring your deals, or reading your operator’s contract very carefully.

Bucket 1: where a real affiliate licence exists

Romania — the flagship

Romania runs the fullest affiliate-licensing regime in Europe: the ONJN Class 2 licence at €20,000 a year plus a €15,000 annual responsible-gambling contribution — about €35,000 all-in. The licence is valid for ten years with annual payments, foreign entities are eligible, and consultancies quote 45–60 days end to end. The trigger is written into the affiliate definition: revenue earned “as a result of the participation in gambling” of referred players, which captures revenue-share and hybrid deals; pure flat-fee media buying is a debated edge case. Once licensed, you file every affiliation contract with ONJN within 15 days, and since Law 141/2025 you may serve Romania-licensed operators only and must submit monthly reports. The full costs, process and obligations are in our Romania affiliate licence guide — and when you are ready to file, you can get the Class 2 licence through our Romania desk.

Greece — suitability licence plus a registry

Greece requires an Affiliate Suitability Licence from the Hellenic Gaming Commission plus entry in the HGC Register of Affiliates, against a €1,000 registration deposit (HGC Decision 509/1/11.09.2020). The lock works both ways: registered affiliates may only serve Greek-licensed operators, and operators may only work with registered affiliates. Details in the Greece affiliate licence guide; to register, use the Greece affiliate licence service.

Gibraltar — marketing became licensable on 1 October 2025

Under the new Gibraltar Gambling Act, providing advertising or marketing services for gambling — wherever in the world the gambling takes place — in or from Gibraltar is now a regulated activity requiring a Gaming Operator Support Services (GOSS) licence. That catches marketing affiliates and group marketing companies based on the Rock; marketing aimed primarily at a Gibraltar audience is exempt. The fee is reported at around £50,000 a year, though the schedule was unpublished at the time of writing. This is the first true affiliate-side licence in a tier-1 hub, and we break it down in the Gibraltar GOSS guide.

Philippines — PAGCOR accreditation

Since 2 October 2025, every B2B provider to a PAGCOR licensee needs accreditation, and marketing and promotional service providers handling player acquisition are expressly in scope as Support Service Providers. The accreditation runs two years and carries a PHP 1,000,000 performance deposit; the compliance deadline for existing suppliers is 31 July 2026. One terminology trap: PAGCOR’s “Gaming Affiliate” category means game-content providers, not marketers.

United States — licensing by deal structure

There is no federal regime. The dominant pattern, confirmed in primary sources across New Jersey, Pennsylvania, Michigan, Colorado and Tennessee, is two-tier: CPA or flat-fee deals get a cheap registration; revenue share gets a full vendor or supplier licence with background checks. New Jersey is the cleanest example — CPA affiliates file a no-fee vendor registration through the operator, while revenue-share affiliates need an Ancillary CSIE licence at $2,000. Pennsylvania’s GSP Certification runs $5,000, Colorado’s Vendor Major is $1,200 plus a $10,000 investigation deposit, and Tennessee sits at the extreme: $150,000 for the first three-year term under fees effective 30 June 2025. At the other end, Ohio, North Carolina and New York require nothing at all, and Indiana stopped enforcing its registration on 1 July 2025. The state-by-state cheat sheet is in our US affiliate licence guide, and we file the registrations through the US affiliate licensing service.

Australia’s Northern Territory and Bulgaria’s pending licence

The NT takes a different route to the same place: under s 81(b) of the Racing and Betting Act, a bookmaker letting anyone share profits without Commission approval commits an offence, so every revenue-share affiliate deal needs NTRC pre-approval with a probity file per affiliate. Flat-fee CPA deals are generally read as falling outside the profit-share trigger. Bulgaria, meanwhile, is one vote away from joining the licence club: the draft 2026 Budget would require affiliates to hold a licence and pay €6,000 a year plus a 10% tax on commissions. It had not been adopted as of publication.

Bucket 2: where affiliates are banned

Five markets have decided the answer to “do affiliates need a licence” is “affiliates should not exist here”.

Finland approved its new gambling act on 16 December 2025 with an exhaustive list of permitted marketing channels — anything not on the list, “including affiliate and influencer marketing”, is prohibited. The licensed market opens 1 July 2027 with affiliates locked out from day one. New Zealand went the same way: its Online Casino Gambling Regulations 2026, in force 3 July 2026, prohibit sponsorships, personal endorsements and affiliate arrangements even for licensed operators.

Belgium got there indirectly: its ad ban, in force since 1 July 2023, allows no compensation to a third party for advertising — which excludes paid affiliate marketing entirely. Italy never banned affiliates by name, but the Dignity Decree’s near-total advertising ban (since 1 January 2019) applies to them directly: no tracked links, no bonus codes, no gambling SEO, with fines of €50,000–500,000 chargeable to the affiliate itself.

Then there are the partial bans. Illinois prohibits revenue-share marketing compensation under 86 Ill. Adm. Code 3000.680(f), and Missouri launched its sports-betting market on 1 December 2025 with the same rule. Affiliates operate legally in both — but on CPA deals only. The ban targets the deal, not the affiliate.

Bucket 3: advertise only with pre-approval

East and West Africa run a third model: no affiliate licence, but a regulator’s gate in front of every campaign. Kenya’s Gambling Control Act 2025 requires prior approval from the new Gambling Regulatory Authority for every gambling advertisement and bans celebrity and influencer endorsements by statute. Tanzania’s Gaming Board issues six-month advertising approvals for companies marketing gaming products, and in Ghana all advertising material needs Gaming Commission pre-approval under January 2025 guidelines. If your traffic model depends on publishing fast and iterating, these are hard markets.

Bucket 4: operator liability — the majority

Everywhere else, the affiliate holds no licence and the operator answers for it. That is not the same as no rules.

The UK looked at affiliate licensing squarely and said no: the April 2023 white paper was “not persuaded”, even though the industry’s own Responsible Affiliates in Gambling group had lobbied for a licence — and the same paper put affiliate-driven acquisition at up to 40% of new customers. Instead, LCCP condition SR 1.1.2 makes operators contract affiliates “as if bound by the same licence conditions” and terminate them promptly for breaches.

The Netherlands is the bucket’s cautionary tale: no licence, but affiliates promoting unlicensed operators commit their own offence, and promoting licensed ones requires a prior written agreement, a genuine opt-out from gambling ads and evidence that at least 95% of the audience reached is 24 or over. The full compliance checklist — and the 2027 outlook — is in our Netherlands affiliate rules guide. Malta makes affiliate and operator jointly responsible for advertising breaches. Curaçao’s LOK leaves affiliates outside the perimeter — the new supplier registration (deadline 24 December 2026) covers critical B2B services and expressly not marketing. Ontario does not register affiliates at all, despite a persistent industry myth about a revenue-share registration tier; the mechanism is the Registrar’s Standards, which make operators responsible for third parties and ban public inducement advertising. Brazil deems affiliate communications to be actions of the operator and requires written contracts in Portuguese.

Two twists worth flagging. Germany bans variable, revenue-based affiliate remuneration for online slots, poker and casino advertising outright — fixed fees only — which quietly kills the standard rev-share model in a licensed market. And Denmark forbids affiliates from displaying the regulator’s own trust label on their sites.

The trigger that recurs everywhere: CPA vs revenue share

Strip away the local detail and one distinction does most of the work worldwide: how you get paid. Michigan’s regulator says it plainly — a revenue-share agreement means a supplier licence, anything else means a vendor registration. Colorado routes any percentage of gaming revenue to the Vendor Major tier. Tennessee defines the licensable vendor as the rev-share affiliate and expressly excludes CPA. Romania’s affiliate definition keys on revenue from players’ participation, the NT’s trigger is profit-sharing itself, and Illinois and Missouri simply ban the model.

The logic is consistent: a flat-fee affiliate is a media seller, but a revenue-share affiliate is an economic partner in gambling revenue — so regulators treat it the way they treat suppliers. The practical consequence: your commercial structure is a compliance decision. Moving a US deal from rev-share to CPA can be the difference between a $150,000 licence and no filing at all — and moving it back can quietly create an unlicensed-activity problem in five states at once.

Enforcement is not theoretical

Every bucket has teeth, and the last eighteen months supplied the receipts.

Romania went further still. On 24 March 2026, ONJN filed a criminal complaint with organised-crime prosecutors against a Class 2 licensed affiliate whose site geo-redirected visitors to unlicensed platforms. A licence covers a defined activity; it does not immunise traffic-funneling.

Note who pays in each bucket. In the Netherlands and Italy, the affiliate itself. In Ontario, the operator — but operator liability means terminated affiliate deals follow the cheque. The UK adds the baseline: LeoVegas’s £600,000 penalty package in 2018 traced 23 of 41 misleading ads to affiliate sites.

What changes in 2026–27

The map is moving, mostly against affiliates. The Dutch government’s draft bill would shrink permitted advertising to almost nothing — the operator’s own site and explicit search results — and ban bonuses, with the role of affiliates explicitly still under study; a first consultation draft is reportedly expected in the first half of 2027. Sweden has a Finance Ministry proposal to attach criminal liability to intermediaries who facilitate unlicensed gambling promotion, proposed to take effect 1 January 2027. Brazil’s regulator has put affiliate advertising on its 2026–27 rulemaking agenda, with an affiliate-specific ordinance expected on top of the July 2026 crackdown that brought tobacco-style warnings and fines up to 20% of revenue. Bulgaria’s draft affiliate licence rides on the 2026 Budget vote, Finland’s licensed market opens 1 July 2027 with affiliates excluded, and Ireland’s B2B licences — covering those who “sell, supply or advertise” — arrive through 2027–28. If you run an affiliate business across markets, at least one of these will touch your 2027 revenue; each gets a dated entry in the Affiliate Licensing Index as it lands.

How to work the map

Start with an inventory: which markets your traffic actually monetises in, and which compensation model each deal uses. Then sort into the four buckets. Bucket 1 is a filing project — Romania Class 2, Greece HGC registration, Gibraltar GOSS, PAGCOR accreditation, US state registrations. Bucket 2 is a structuring decision: exit, or switch to CPA where that remains lawful. Buckets 3 and 4 are contract and process work — pre-approval workflows, written agreements, audience evidence.

This is what we file at Vantegris: affiliate licensing and registration across Romania, Greece, Gibraltar, the Philippines and the US state registrations, with the fee maths cross-checked against our Fee Index. If you are not sure which bucket your model lands in, the licence finder narrows it down in a few clicks — or tell us your markets and we will map them for you.

This article is general information, not legal advice. Affiliate rules are changing fast through 2026–27, and several figures cited here come from draft legislation or reported fee schedules — we confirm the current position for your markets at scoping.

This article is for general informational purposes only and is not legal, tax or financial advice. Consult a qualified professional before acting.