Affiliates Are No Longer Just Ad Platforms: Who Will Be Next to Face Licensing?

For a long time, iGaming regulation was built around the operator. It was the bookmaker or casino that obtained a license, underwent checks, paid specific taxes, and was accountable to the state for handling players. Affiliates, influencers, ad platforms, and payment providers, meanwhile, remained service providers that formally stayed outside the main regulatory perimeter.

In 2026, this framework is changing noticeably. States are increasingly taking the view that controlling a single operator is no longer enough. A player may see an ad from a blogger, follow a link from an SEO site, make a deposit through a payment intermediary, and start playing on an offshore platform. If the regulator only monitors the company that accepts the bet, a significant part of the acquisition and monetization chain remains beyond its reach.

That's why the new regulatory perimeter now covers not just the gambling product itself, but also the infrastructure around its distribution: affiliate sites, influencers, ad accounts, apps, internet platforms, and payment institutions. For affiliates, this is a fundamental shift. They are gradually ceasing to be seen as independent ad channels and are becoming participants in the regulated gambling market.

On 3S.INFO, we break down how iGaming regulation in 2026 is moving beyond operator licenses and starting to cover the entire player acquisition chain, including affiliates, influencers, ad platforms, payment services, and technical providers. 

• What is an affiliate license? It is an official document for those engaged in client acquisition for brands. In our new guide, we provide a detailed step‑by‑step breakdown covering who needs it, why it is required, in which jurisdictions it is mandatory, and how to complete the application process. 

Why Operator Licenses Are No Longer Enough for Regulators

The traditional model assumed that the operator was fully responsible for its advertising. If an affiliate used a prohibited creative or an influencer promised followers guaranteed earnings, claims were first directed at the licensed brand.

• In iGaming, two main types of licensing documentation are distinguished: offshore and local. Their key difference lies in the approach to jurisdiction, which directly affects available markets, tax burden, regulatory requirements, and user trust. We've prepared a concise comparative analysis that serves as a quick reference guide for determining the direction of business development.

However, this system has a clear limitation. An operator can control its own campaigns and major partners, but not the entire distributed promotion network. Content gets copied, domains are changed, traffic is resold through multiple intermediaries, and ads may end up being placed by a party the operator never directly contracted with.

This problem is especially visible in the unlicensed operator segment. A brand deprived of the right to advertise officially can still buy traffic from SEO projects, Telegram channels, streamers, or influencers. The formal ban on the operator remains in place, but the acquisition channel keeps working.

Regulators are responding by shifting from controlling individual legal entities to overseeing the entire business chain. Under the new model, liability may arise not only for the party accepting the bet, but also for those who helped display the ad, attract the player, process the payment, or maintain access to the illegal platform.

Brazil: Operators Are Now Liable for Influencer Ads

Brazil is one of the most telling examples of this approach. Federal Law No. 14.790/2023 introduced requirements for betting advertising and prohibited the promotion of unlicensed operators, unfounded promises of winnings, and the portrayal of betting as a source of income, investment, or a solution to financial problems.

The law extends responsibilities to internet infrastructure as well. Ad companies and internet application providers must remove illegal campaigns after receiving a notice from the Ministry of Finance. Platforms that distribute third‑party apps are also required to remove illegal gambling products within the technical capabilities of their service.

In 2026, the Secretariat of Prizes and Betting (SPA) included a review of advertising requirements on its regulatory agenda. A key focus of the discussion was affiliate channels and influencer campaigns. For now, the primary legal responsibility for such placements rests with the licensed operator. Official clarifications suggest that operators may be held liable for misleading or aggressive advertising disseminated by bloggers they have engaged.

The regulation also covers creative content. Ads must include age labeling and a warning about the risks of addiction. The warning block must take up at least 10% of the ad's size. Wherever the ad format allows, the warning should be provided in both written and verbal form.

Statements that create the impression that betting can ensure financial independence, additional income, or professional success are prohibited. Unsubstantiated claims about the likelihood of winning or the potential size of a player's earnings are also not allowed.

For influencers, this fundamentally changes the nature of collaboration. Previously, they could see themselves as owners of an audience who simply sold an integration to an operator. Now, the content of the post becomes part of regulated advertising, while the operator needs to control not only the materials provided to the blogger but also the actual result of the placement.

Brazil has not yet introduced a separate gambling license for influencers or traditional affiliates. Nevertheless, the direction of travel is clear: the affiliate channel is no longer seen as a neutral platform, but as part of the operator's advertising activity. Further expansion of direct liability for advertisers appears possible, though for now it remains a forecast rather than an established norm.

Bulgaria: Affiliates Are Becoming Independent Market Participants

Bulgaria is going further, shaping a model in which gambling affiliates become independent licensing entities.

Bulgarian lawmakers have approved a regime for affiliates receiving performance‑based remuneration for promoting licensed operators. This covers CPA, Revenue Share, and Hybrid agreements (models where remuneration depends on referred players, deposits, bets, or operator revenue). Standard advertising purchased at a fixed rate does not fall under this regime.

Key parameters of the regime include an annual fixed fee of approximately €6,000. In addition, the operator is required to withhold and remit to the National Revenue Agency (NRA) a sum equal to 10% of the affiliate's performance‑based remuneration on a monthly basis. It's therefore more accurate to refer to it not simply as a "commission tax," but as a 10% withholding + a fixed levy.

Timing is important here. The regime was introduced through amendments to the Gambling Act as part of the 2026 State Budget Act, published on July 31, 2026. The rules came into force on August 1, 2026, and affiliates already active in the market were required to submit license applications by August 15, 2026, in order to continue operating without interruption. The short deadline left businesses no room to treat the changes as a long‑term compliance project.

The license is issued for 5 years and applies to both Bulgarian and foreign companies and individuals. Foreign affiliates are required to appoint a local representative with a registered address in Bulgaria and disclose all online channels used for promotion, including websites and social media.

Sanctions are severe: operating without a license carries fines ranging from €5,000 to €20,000. In addition, authorities may fully confiscate the affiliate's revenue and block their promotional channels.

That said, the practical mechanics of applying the requirements to Hybrid contracts, foreign entities, and negative Revenue Share periods will need to be reconciled with the final instructions from the NRA.

The Cost of Bulgaria's Affiliate Licensing Model

With a 10% withholding taken directly from the partner's payout and an annual fixed fee of €6,000, the burden on smaller affiliates will be disproportionately high.

At €20,000 in annual commission revenue, the operator will withhold €2,000, and an additional €6,000 will be required for market access. Total regulatory costs would reach €8,000, or 40% of affiliate revenue, before even accounting for salaries, content production, traffic acquisition, servers, and standard business taxes.

At €50,000 in annual commissions, the total burden would be €11,000, or 22%. At €100,000, it would drop to 16%, and at €300,000, to 12%.

This is a scenario‑based calculation based on the published parameters of the reform. The actual burden will depend on the final legal structure of payments, the contract terms with the operator, and the affiliate's other tax obligations.

Even this rough estimate, however, reveals the core effect of the model. The fixed fee makes it regressive: the smaller the affiliate, the larger the share of revenue absorbed by regulation.

Affiliate Licensing: Where Is the Break‑Even Point?

An affiliate's commission is not the same as its profit. A significant portion of revenue goes toward advertising, editorial content, SEO, analytics, technical infrastructure, and salaries. For projects that rely on paid or costly traffic, the real impact will be far greater than a simple ratio of levies to commissions suggests.

If operating costs account for 70% of affiliate revenue, and the new levies are calculated under the model described above, the project would break even at roughly €30,000 in annual commissions. With operating costs at 80%, the break‑even point would rise to about €60,000, and at 85%, it would reach €120,000.

For example, at €60,000 in revenue and 80% operating costs, the affiliate would be left with €12,000. Of that, €6,000 would go toward the fixed fee, and another €6,000 toward the 10% withholding. The resulting profit would be zero.

The highest risk zone includes paid traffic sources with thin margins, new SEO projects, local content sites, individual tipsters, and affiliates dependent on a single GEO. Large portals, multi‑geographic networks, and owners of stable organic traffic will find it easier to weather such a model.

Licensing Will Become a Size Filter

Formally, the license is meant to make the market more transparent. Regulators will be able to determine who is authorized to promote gambling products, require disclosure of owners and channels used, audit partner activities, and exclude affiliates that simultaneously promote offshore brands from the legal segment.

In practice, the fixed fee turns the license into an economic filter as well. It has little impact on large affiliate groups but sharply raises the entry barrier for smaller projects. As a result, regulation may lead not only to a reduction in illegal promotion but also to consolidation of the legal affiliate market.

Smaller sites will need to merge, sell traffic through licensed networks, or exit the GEO. Some projects may try to shift from CPA and Revenue Share to fixed‑fee ad contracts. Under available descriptions of the Bulgarian regime, flat‑fee arrangements without a performance component may fall outside the same requirements. However, the final classification of such contracts must be determined by law and regulatory guidance, not by the payment label in the contract.

For operators, a reduction in the number of partners won't necessarily be good news either. Compliance will become simpler. Instead of hundreds of small webmasters, they can work with a few verified groups. At the same time, the bargaining power of the largest affiliates will increase, traffic source diversity will shrink, and the cost of player acquisition may rise.

How Payment Infrastructure Becomes a Regulatory Lever: The Philippines

In Asia, regulators often act not through a separate affiliate license, but through infrastructure‑based pressure. The goal is to limit the ability of gambling businesses to advertise, distribute apps, access payment services, and maintain contact with local audiences.

In the Philippines, the ban on Philippine Offshore Gaming Operators (POGO) was fully implemented by the end of 2024. The decision was linked, in particular, to identified cases of fraud, money laundering, and other criminal activity surrounding the offshore sector.

In August 2025, the Central Bank of the Philippines further required banks, e‑wallets, and other supervised institutions to remove from their apps and websites any links, icons, and features that directly redirected users to gambling platforms. Financial institutions were given 48 hours to comply.

This measure did not mean a complete ban on payments to licensed operators. Users could still fund gambling accounts through supported payment methods. However, the regulator removed the built‑in shortcut that effectively turned the e‑wallet into a gambling distribution channel.

The case showed that financial infrastructure is no longer viewed as a completely neutral intermediary. Regulators can influence the market not only through operator licenses, but also through banking and e‑wallet interfaces, the availability of payment scenarios, and the distance between the user and the bet.

The effect was noticeable. According to PAGCOR, in the first days after the removal of embedded links, online gambling transaction volumes dropped by approximately 50%. This was a preliminary short‑term indicator rather than confirmed long‑term dynamics, but it clearly demonstrates the impact of payment UX on gambling conversion.

Japan: Affiliate Links Are Now Under Direct Ban

In Japan, the key changes came earlier. In June 2025, parliament passed amendments to the Basic Act on Measures Against Gambling Addiction, which took effect on September 25 of the same year.

The law prohibited displaying illegal online gambling sites and apps to Japanese audiences, as well as publishing information that directs users to such services. The restrictions cover internet advertising, affiliate links, social media, intermediary "reach sites," rating sites, and curated lists of online casino recommendations.

An important nuance of the mechanism is that the law does not introduce specific criminal penalties for violations. Its strength lies elsewhere: it allows the police, internet providers, and social platforms to actively demand the removal of promotional content and take it down. The primary enforcement tool is not a fine, but forced removal of placements and pressure on infrastructure.

The National Police Agency of Japan specifically classifies payment intermediaries and affiliates as participants in the infrastructure of illegal online gambling. In the Police White Paper 2025, affiliate advertising is cited as the predominant method of promoting the investigated online casinos, with partners receiving payouts based on user registrations.

This is an important precedent for content‑based affiliates. The restrictions may apply not only to banners or direct calls to register, but also to ratings, reviews, or comparison sites if their purpose is to direct Japanese users to illegal operators.

At the same time, it should not be claimed that Japan has introduced a universal obligation for all payment companies to block gambling‑related transactions. Official materials confirm police attention to payment intermediaries and their possible involvement in illegal activity, but this is not the same as a separate, comprehensive payment blocking regime.

Brazil Brings the Financial Sector Into Enforcement

Brazil goes further in regulating payment infrastructure. Law No. 14,790 prohibits financial institutions, payment organizations, and payment scheme participants from processing transactions destined for unauthorized betting operators.

In 2026, the legislation was reinforced with mechanisms for blocking accounts of illegal market participants. Financial and payment institutions are now required to block such accounts and prevent new transactions that could directly or indirectly support unauthorized betting activity. The operating procedures for these blocks are being developed in coordination with the Central Bank and the Ministry of Finance.

In this system, the payment provider becomes part of state enforcement. It is no longer enough to simply process a technically valid transaction. The provider must also determine whether it supports unauthorized gambling activity.

For the market, this means additional merchant checks, transaction monitoring, data sharing with government agencies, and the risk of being blocked if the business is misclassified. At the same time, operators and affiliates become more dependent on the quality of the data used by banks and payment systems.

Who Else Is at Risk of Regulation?

If we look at the measures already adopted in Brazil, Bulgaria, Japan, and the Philippines, further regulatory tightening could affect four main groups.

1. Affiliates, influencers, tipsters, and streamers directly influencing a player's decision to register and make a deposit. Bulgaria has already introduced independent licensing for such participants, Japan directly restricts affiliate promotion of illegal casinos, and Brazil ties influencer advertising to operator liability.
2. Advertising and technology platforms. In many countries, they are currently required to remove illegal campaigns upon notification. The next possible step could be mandatory verification of the advertiser's license before a placement is launched.
3. Payment institutions. In some jurisdictions, this process has already begun. Brazil has codified financial sector obligations into law, while the Philippines has used e‑wallet interface regulation to limit the accessibility of gambling products.
4. Technical infrastructure providers, including hosting companies, white‑label platforms, CRM systems, game aggregators, and other operators serving gambling businesses. If such a provider knowingly supports illegal operations, regulators will find it increasingly difficult to treat them as a neutral contractor not responsible for their client's activities.

This is not a unified sequence officially established by regulators. In each country, controls develop differently. Some jurisdictions move first to license affiliates, others start with payment blocks, ad restrictions, or app removals. But the overall direction is consistent: states are targeting the critical nodes without which illegal gambling businesses cannot attract and monetize players.

What's Changing for Affiliates Right Now

The main risk lies not only in licenses and new fees. Affiliates will need to reshape their entire operating model. For each GEO, they must verify the operator's licensing status, permitted ad formats, bonus rules, mandatory warnings, age restrictions, and responsible gambling requirements.

The date of verification becomes especially important. An operator's license may be suspended or revoked, and advertising requirements may change while a campaign is already running. A one‑time check at the time of signing a contract is no longer enough.

The contract with the operator also becomes a compliance tool. It needs to specify who approves creatives, who tracks legislative changes, who notifies about licensing issues, and what happens to earned commissions if a violation is identified.

It's equally important to rule out retroactive application of requirements. If, after the reporting period, the operator claims that traffic was acquired in violation of a new internal policy, the affiliate has virtually no way to verify the validity of the non‑payment. That's why expanding government regulation must be accompanied by transparent criteria from advertisers.

Compliance should not become a catch‑all excuse for withholding commissions. A violation must be tied to a specific rule that was in effect at the time of placement, a specific traffic source, and demonstrable harm or regulatory risk.

The New iGaming Landscape: More Transparent, But Costlier

There is a clear logic behind expanding the regulatory perimeter. It is impossible to effectively control gambling if restrictions apply only to the operator, while advertising, payments, and player acquisition remain in a gray zone. Holding intermediaries accountable can indeed reduce the promotion of unlicensed brands and overtly manipulative campaigns.

The problem begins when the same fixed requirements are applied to businesses of vastly different scales. A license costing €6,000 may be a negligible expense for an international portal but an insurmountable barrier for a local site. The additional commission withholding only widens this gap.

As a result, under the guise of market cleanup, the state risks ending up with a market dominated by a few large affiliate groups. They will be able to spread compliance costs across countries and projects, while smaller independent sites will be forced to shut down, move to other GEOs, or operate through intermediaries.

Affiliates are indeed no longer just ad platforms. They are becoming part of the regulated player acquisition infrastructure, with licensing, audits, payments, and their own accountability. The key question is no longer whether partners will face tighter control, but what form that control will take: whether it will be proportionate to risks and business scale, or designed only for those already large enough to afford staying in the market.