The reform of the Finnish gambling system – the new model for licenced operations opens up competition and brings new opportunities for marketing and advertising

Finland’s gambling system is undergoing reform. The objective of the reform is both to prevent gambling-related harm and to channel gambling activity towards supervised and authorised offerings. The introduction of a licensing system will take place in stages during 2026 and 2027. The majority of the legislation is intended to enter into force on 1 July 2027, while the provisions for applying for a license to operate have entered into force already on 1 March 2026.

The reform of the gambling system will bring changes to, i.a., the marketing and advertising of gambling: soon, betting and online casino games may be marketed relatively broadly across different channels, although certain restrictions will remain. In the Nordic context, Denmark adopted a partial licensing system for gambling already in 2012, and Sweden followed with a comparable reform in 2019. The experiences in Denmark and Sweden regarding market developments after the respective reforms have been taken into account in the Finnish Government Proposal.

Licensing timeline

From 1 March 2026 onwards, gambling operators may apply for a gambling licence from the National Police Board. Veikkaus Oy’s monopoly for offering gambling services will end at the end of June 2027 with respect to online betting and online casino games, once licensed operators may commence their authorised operations on a competitive market. Veikkaus Oy will, however, retain its monopoly to lottery-type draw games, scratch cards, as well as physical slot machines and casino games, but it must apply for a licence for such exclusive operations. Veikkaus may also apply for a licence to provide gambling services on the competitive market.

What should gambling operators consider with respect to marketing?

One of the most central topics in the revision of Finnish gambling legislation is the marketing and advertising of gambling services. What makes the regulation of marketing particularly challenging for gambling is the objective of striking a balance between a) preventing and reducing gambling-related harm and b) ensuring the ability of the system to channel players to choose the services of supervised and authorised businesses.

Although only limited research exists that would reliably assess the effects of gambling marketing on gambling volumes or related harm, literature typically indicates a positive correlation between exposure to advertising and both the amount of gambling and the prevalence of problematic gambling. It has also been reliably demonstrated that gambling advertising increases sales of gambling products (Karjalainen et al.: Pohjoismaiset rahapelijärjestelmät ja niiden vaikutukset. KKV 3/2024).

Permitted marketing channels

Once licensed operations commence, operators holding a licence may market the games that may legally be offered under Finland’s licensing regime. The regulatory reform emphasises that marketing must be “moderate and responsible” in both content and volume. Marketing may not give a misleading impression of gambling or encourage excessive gambling. A similar approach has been adopted in Sweden.

Channels in which marketing would be permitted in the future include, i.a.:

1. The gambling operator’s own digital channels – for example, the operator’s own websites and mobile applications.
2. Traditional media, including the online versions of such providers – such as television, radio, newspapers, magazines, and newspaper websites and other editorial online media.
3. Event environments and outdoor advertising – for example, digital screens and billboards, as well as sports and event sponsorships.

Content requirements: moderate and responsible

In addition to ensuring that marketing is directed only to permitted channels, it is important to ensure that the content of marketing is compliant with the law. Ensuring that marketing is moderate is particularly essential. For example, marketing may not suggest that winnings are guaranteed or that gambling could alleviate financial difficulties.

The Government Proposal examines similar developments in Sweden, where gambling marketing must also be “moderate” (“måttfullhet”). In Sweden, it has been considered that marketing is in violation of this requirement where an advertisement encourages immediate play or implies that a player’s skills can influence the outcome of a game. Furthermore, the statement “Winnings in your account in five minutes” was found to violate the Swedish moderation requirement (Dom i målet KO — Elec Games (Ninja Casino), 22.11.2019). Swedish case law has also considered marketing to be contrary to the moderation requirement where the marketer failed to clearly disclose restrictions related to free spins and bonuses (Dom i målet KO — AG Communications (Karamba), 9.11.2020). According to the guidelines issued by the Swedish Consumer Agency, bonuses related to gambling may also not be offered during gameplay, nor may gambling be offered for purchase on credit.

Prohibited marketing methods

Although several methods of marketing will be permitted, the Finnish legislative reform expressly prohibits the following types of marketing, in addition to the general requirements of moderation and responsibility:

1. Influencer marketing – gambling operators may not cooperate with social media influencers in a manner where influencers actively promote gambling in their own social media channels. A sponsored individual or team may, however, display the logo of the sponsoring gambling operator in their channels, provided that gambling products themselves are not featured. This prohibition is closely linked to concerns that marketing of gambling services by social media influencers, artists, and other well‑known public figures is particularly harmful to minors. Such marketing typically takes place on platforms predominantly used by young people and minors, and the influencers and celebrities involved are often individuals whom younger audiences in particular follow and admire.
   
2. Direct marketing without the individual’s explicit consent – a gambling operator’s customer relationship may not, for example, automatically include consent to direct marketing, nor may consent be “hidden” within contractual terms unrelated to direct marketing.
   
3. Affiliate and partnership marketing – the reform prohibits commission-based online redirection to gambling websites. According to the Government Proposal, the use of affiliate marketing as a marketing tool could blur the distinction between licensed operators and illegal providers and enable abuses, particularly in relation to mandatory information that must be included in marketing communications.
   
   Affiliate marketing is a common customer acquisition method in the gambling sector. Typical forms of affiliate marketing include various themed websites, such as sports‑related or hobby‑focused news and topical sites. These sites are often presented as informational, but their actual primary purpose is to direct users to gambling operators’ websites through identifiable links, codes or other tracking mechanisms. Players are frequently attracted by various promotional offers, and such sites are most commonly found via search engines. In affiliate arrangements, the website operators are remunerated based on redirected traffic, for example according to visitor numbers, newly registered customers, gambling losses incurred by those customers, or a combination of these criteria.
   
4. Marketing may not target minors or other vulnerable groups, nor may minors appear in any marketing materials. This also means that sponsorship agreements may not be concluded with individuals under 18 years old, or in relation to events, competitions or leagues involving persons under 18 years old.

Outlook

Notably, in their consultation responses concerning the proposed reform, gambling sector operators have stated that prohibiting affiliate marketing would be detrimental to the channeling of gambling to supervised and authorized operators, particularly in situations where gambling companies operating outside the licensing system continue to make use of affiliate marketing. From the perspective of industry representatives, the prohibition on affiliate marketing is therefore likely to prove sufficiently problematic, and gambling operators may seek to amend the legislation in this respect at a later stage.

As with Sweden’s moderation requirement, it is likely that the Finnish requirements concerning moderate and responsible marketing will involve interpretive uncertainty and challenges regarding the definitions of the relevant terms. After the commencement of authorised operations under the new licensing system, it can be expected that regulatory guidance and case law will further clarify the boundaries applicable to gambling marketing.