UK AND ONTARIO · AFFILIATE MARKETING
Enforcement cases involving affiliates and third parties
Regulators rarely act against affiliates directly; they act against the operator whose brand the affiliate promoted. In 2025 and 2026, the clearest published cases came from the ASA in the UK and the AGCO in Ontario, and each one placed responsibility on the operator.
- Three ASA rulings from 2025 to October 2026 involved an affiliate making or publishing the ad; all three were upheld.
- In Ontario, BetMGM's C$110,000 penalty (March 2025) covered cash inducements offered to new customers, including through contracted third parties.
- We found no Gambling Commission sanction centred on affiliate marketing in 2024 to October 2026.
- In every case, the operator or the advertiser named in the decision carried the responsibility.
Published enforcement involving gambling affiliates is limited, and it points one way: the brand being promoted is held responsible for what its marketing partners publish. From January 2025 to October 2026, the Advertising Standards Authority upheld three rulings in which an affiliate made or ran the ad, and Ontario's regulator penalised BetMGM for inducements that included offers made through third parties. We found no Gambling Commission case focused on affiliates in the same period, although its licence conditions make operators responsible for third parties they contract with.
ASA rulings involving affiliates
| Date | Advertiser | What happened | Outcome | Ruling |
|---|---|---|---|---|
| 27 May 2026 | Cyan Blue Odds Ltd (Oddschecker) | Instagram posts featuring Harry Kane and Erling Haaland from an odds-comparison service that sends users to bookmakers; strong appeal to under-18s reasoning applied | Upheld | ASA |
| 9 Sep 2026 | Smart Gravity Ltd (top10onlinecasinoreviews.co.uk) | Paid search ad for an affiliate casino comparison site appeared for the query "help with gambling" | Upheld (social responsibility) | ASA † |
| 16 Sep 2026 | Dribble Media Ltd (Midnite) | TikTok ad made by the affiliate Limay Media showed an AI-generated character who appeared under 25 gambling; Midnite ended the contract | Upheld (rule 16.3.14) | ASA |
Two lessons stand out. The Midnite case shows that an affiliate's creative choices, here an AI character, are treated as the operator's ad, and the ruling records the operator's response. The Smart Gravity case shows that keyword targeting is assessed for social responsibility: a casino ad appearing for a search about getting help was found irresponsible, regardless of whether the ad's wording broke any rule.
Ontario: inducements through third parties
Ontario restricts the advertising of inducements, bonuses and credits to new customers under Standard 2.05 of the Registrar's Standards for Internet Gaming. On 26 March 2025 the AGCO issued a C$110,000 penalty against BetMGM Canada for offering cash to induce new customers, including through contracted third parties. Before the 2023 window, the AGCO penalised DraftKings, BetMGM, PointsBet and Unibet in 2022 for advertising inducements. The full list is in our AGCO penalties tracker.
Great Britain: where responsibility sits
The Gambling Commission's guidance on affiliates states that licensees must take responsibility for the third parties they contract with, and its Licence Conditions and Codes of Practice require operators to ensure third parties comply with marketing rules. Its 2024 to 2026 enforcement, listed in our Commission tracker, centred on money laundering and safer gambling; the marketing cases in that period (Tombola and Grace Media) concerned the operators' own direct marketing consent, not affiliates. Advertising content by affiliates is mainly policed through the ASA.
What these cases suggest operators check
The cases point to four checks an operator can evidence: who creates affiliate content and whether it is reviewed before publication; which search terms and placements affiliates buy, including exclusions for help and recovery terms; whether people shown in affiliate creative are, or appear, under 25; and whether offers made through partners comply with local inducement rules. Our regulatory evidence record sets out a way to document those checks against each rule.
Questions about affiliate enforcement
Can a gambling operator be held responsible for an affiliate's ad?
Yes. In the ASA cases above, the advertiser named in the ruling was responsible, including where an affiliate made the ad. The Gambling Commission and the AGCO also hold licensees responsible for third parties they contract with.
Has the Gambling Commission fined an operator for affiliate marketing recently?
We found no Commission sanction centred on affiliate marketing between January 2024 and October 2026. Earlier cases exist, and affiliate content is regularly assessed by the ASA.
Sources
- ASA rulings linked in the table
- AGCO: C$110,000 penalty on BetMGM Canada (26 March 2025)
- Gambling Commission: affiliates and third parties
- CAP News: six tips for gambling marketers, including affiliate accountability (27 November 2025)