Marketing Under The Finnish Gambling Licence, 2027

What a licensed gambling operator may lawfully publish in Finland from 1 July 2027, what the Act prohibits outright, and what is still undecided. Written for the people who commission marketing, not for lawyers.

Position paper 01

Jurisdiction	Finland
Instrument	Rahapelilaki (Gambling Act 10/2026), Chapter 4
Version	1.5
Issued	15 September 2026
Next review	On the Police Board marketing regulations, expected before end 2026
Author	Gloria Kesa, finestverba.com

Five things to decide before the budget is written

Finland is not another Nordic opening with different paperwork. The restriction set is tighter than the comparable EU and Nordic markets, and it arrives at the same moment as the competition that always follows a market opening. A plan carried over from Sweden, the Netherlands or Ontario will not survive contact with it.

The main player acquisition system is gone. Affiliates, influencers and welcome bonuses are all outside the permitted set. Those three mechanics carried every previous Nordic launch. There is no reduced or supervised version of them to fall back on, so the entry model has to be rebuilt rather than adjusted.
Media prices are rising, and the published figures are a floor. Commentary in the market has described increases of around twenty percent. Treat that as the bottom of the range rather than as an estimate. Demand from every licensed entrant concentrates onto a small number of permitted channels at the same moment, and the published commentary predates that concentration. A budget built on the twenty percent figure is built on the most optimistic number available. Reasoning, not a sourced rule.
Rising prices meet a cap on volume. Marketing must stay moderate in extent, visibility and frequency. Spending your way past the competition is not available even to an operator willing to pay. Budget buys quality of position rather than quantity of exposure, which inverts the usual relationship between money and share of voice at a market opening.
Expect competitors who are not trying to make money. A meaningful share of entrants will budget for loss through the first year and beyond, buying position rather than return. This happens at every market opening. It matters here because an entry priced for first-year profitability will lose share to entrants who are not attempting any, in a market where the cheap acquisition channels no longer exist to close the gap later.
What survives is owned, earned and brand. The permitted list pushes value back onto the operator’s own domain, brand-level presence, and a CRM that can prove it is compliant. These compound over time and they are the only assets that cross 1 July 2027 with nothing to retire. Everything bought in the meantime becomes an inventory to clean up.

Dated, and the reason not to finalise a media plan yet

The National Police Board is drafting marketing-specific regulations and expects to publish them before the end of 2026. Reported from the Board’s own presentation at a recent Rahapeliala ry seminar. Several of the questions this paper marks as open in section 8, including how the moderation standard will be measured, are the questions those regulations exist to answer.

A plan built now against the statute alone will need a second pass. Build the parts that do not depend on the open questions, which is owned content, entity and brand work, and hold the media commitments until the regulations land.

The budget question is not how much to spend on acquisition. It is how much to spend on assets before the channels close, and whether the organisation can be persuaded to fund something that does not report a cost per acquisition.

The dates that set the deadline
The permitted channels are an exhaustive list
What the Act prohibits by name
Content restrictions and mandatory disclosures
The moderation standard, which outlasts everything else
The period before 1 July 2027 is not a free window
Common activities, assessed
What is still open
What to do in the ten months remaining

1. The dates that set the deadline

Licence applications opened with the National Police Board on 1 March 2026. The application fee is EUR 29,000 at the 2026 rate.

Fifty applications had been received by 8 June 2026, the majority from foreign operators. More than sixty are now pending, on the Police Board’s own account at a recent Rahapeliala ry seminar. Because of that volume the Board is quoting an average processing time of six months, which supersedes the three to six month range published earlier. An operator that has not filed is now behind more than sixty others in a queue that is lengthening.

The first licences enter into force on 1 July 2027, which is also the date licensed operations may begin and the date the Finnish Supervisory Agency takes over supervision from the National Police Board.

Until that date, Veikkaus Oy retains the monopoly and the operation and marketing of gambling by any other operator remains prohibited in Finland. Section 6 deals with what that means for campaigns run in the meantime.

2. The permitted channels are an exhaustive list

This is the structural point that most entry plans get wrong. The Act does not describe prohibited marketing and permit the rest. It names the channels a licensee may use, and anything not named is prohibited.

The operator’s own website.
The operator’s own social media accounts, on a non-interactive basis.
Television and radio.
Sports events and other public events.
Print media and equivalent digital publications.
Gaming premises, for games available at that location.
Search engine advertising using keywords directly related to the operator or its games.

Outdoor is brand, not product. Outdoor advertising in the competitive market is permitted at brand level only. Marketing of betting and online casino products themselves is not within the section 51 permission. Location restrictions apply on top of that, so brand outdoor may not appear near schools, pharmacies, healthcare centres, rehabilitation facilities or educational institutions. Events are the exception where games may appear off the operator’s own properties.

The practical consequence for a media plan: an outdoor buy can carry the operator’s name and brand identity, geo-fenced away from the restricted locations. It cannot carry a game, a product, or anything that reads as an invitation to bet.

Read the search engine line carefully. Keywords must relate directly to the operator or its own games. Bidding on generic category terms is not covered by the permission.

One correction to a common reading: trade coverage sometimes states that licensees may advertise their brand but not their games. That is too broad. Games may be marketed in several of the listed channels, subject to the content restrictions in section 4 and the moderation standard in section 5.

3. What the Act prohibits by name

Affiliates and influencers are out, and the mechanism matters if you are arguing the point. Neither survives as a lawful channel. The route there is the closed list rather than a standalone prohibition: a named affiliate clause was dropped during drafting, so affiliate activity is excluded because it is not a listed channel. Influencer activity is excluded by the combination of the own-account and non-interactive rules, supported by the Ministry Q and A. For a media plan the outcome is what counts. For a conversation with someone who has read the Act and cannot find the clause, the mechanism is what counts.

Bonuses split by purpose, and the distinction is the whole point. As acquisition marketing they are prohibited: welcome offers, free play, deposit bonuses, discounted play and bundled incentives are all out, which removes the mechanic most operators build a Finnish launch around. As retention to a customer with an established relationship, bonus play money is permitted, provided it is moderate, offered on equal terms, carries a wagering requirement no higher than five times the bonus amount, and is not tied to the amount of money or time the customer has spent gambling. Non-gambling benefits of moderate value, such as an event ticket or a discounted product, are also permitted to established customers.

Two things to settle before anyone writes a reload offer. An established customer relationship is a statutory concept and it is not defined as simply having an account, so counsel should pin what it means for your product before a day-two reload is designed. And a permitted retention bonus that is advertised is still the marketing of a bonus. A ten euro credit for existing players is lawful as a message to that customer and unlawful on television.

Direct marketing has three screens, not one. Prior explicit consent is required. Telephone direct marketing is prohibited; text messages are permitted where consent exists. On top of consent, marketing may not be targeted at a person who has set a block on all gambling, or who has not played that licence holder’s games during the preceding two years. Read the second limb carefully: it is the operator’s own games, not gambling anywhere. A player who bet with Operator A last month and has never used Operator B is off Operator B’s direct list even with consent on file. Where a block is game-specific rather than total, only marketing of the unblocked games may be sent.

This is a segmentation requirement rather than a copy requirement, and it has an operational cost. A CRM list that has not been screened against a two-year window of activity on your own games is non-compliant however careful the message is.

4. Content restrictions and mandatory disclosures

A permitted channel does not make the message permitted. Marketing content may not portray gambling positively or as an ordinary part of everyday life, may not suggest that gambling improves social standing, may not offer credit or financial instruments for gambling, may not misrepresent the chances of winning, and may not target minors or feature people who appear to be under age.

For a content team used to writing conversion copy, the practical effect is that most standard casino marketing language fails on the first restriction alone. Social standing is a paraphrase here of the statutory limbs on desirability and everyday life rather than a term used in the Act.

Every communication carries mandatory disclosures. Section 55 requires each marketing communication to state the legal age limit and where to find play-management tools and help for gambling problems. Counsel also treat the licence holder’s identity and the supervising authority as required. A production brief written from the content restrictions alone will ship advertisements without the statutory footer, which is a compliance failure independent of anything the copy says.

5. The moderation standard, which outlasts everything else

Marketing must remain moderate in its extent, scope, visibility and frequency, and must not be particularly attention-grabbing or highly visible, or occur with particular frequency.

That standard applies to lawful marketing in permitted channels. A campaign can therefore be built entirely from permitted channels and still breach the Act because of its size or repetition. Any plan whose value comes from volume is exposed to this even when every individual placement is defensible.

Enforcement tools include administrative penalty payments, blocking or removal of domains and of marketing content, licence revocation, and criminal liability where applicable.

6. The period before 1 July 2027 is not a free window

A common assumption is that the restrictions begin when the licences begin, leaving a period in which operators can build Finnish presence unhindered. That reading is wrong on the current law.

Marketing gambling to Finland by any operator other than Veikkaus is prohibited today. Enforcement has been weak, which is not the same as permission. The period ahead is an under-enforced prohibited period that becomes an enforced one, not a permitted period that closes.

The applicant-specific risk is sharper. Licence applicants are assessed against fitness and propriety criteria, and the disqualifying factors include incurred penalties for unlicensed gambling operations and a gambling licence revoked within the previous three years. An applicant running a visible Finnish campaign is conducting prohibited marketing while its character file sits open with the authority that will decide its application.

There is also a persistence problem that campaign planning tends to miss. Enforcement includes removal of marketing content, and a paid placement bought in 2026 is still marketing on 2 July 2027 if it remains live. Anything built now becomes an inventory the licensee has to identify and retire before its licence takes effect.

7. Common activities, assessed

Verdicts below apply to a licensed operator marketing gambling to Finnish consumers from 1 July 2027. Conditional means the activity can be lawful in a specific form and unlawful in its usual form.

Activity	Verdict	Basis
Guides and responsible gambling content on the operator’s own site	Permitted	Named channel. Content restrictions still apply to the copy.
The operator’s own social accounts	Conditional	Permitted on a non-interactive basis. Comment threads and community management sit outside that wording.
Search ads on the operator’s brand and its own game names	Permitted	Keywords directly related to the operator or its games.
Search ads on generic category terms	Prohibited	The permission is limited to keywords directly related to the operator or its games. Category terms are neither.
Television, radio, print and equivalent digital publications	Permitted	Named channels, subject to the content restrictions and the moderation standard.
Affiliate placements on revenue share or CPA	Prohibited	Not a listed channel. The named affiliate clause was dropped in drafting, so the prohibition operates through the closed list rather than a standalone section.
Influencer, streamer and creator partnerships	Prohibited	Excluded by the own-account and non-interactive rules, supported by the Ministry Q and A.
Paid guest posts and sponsored articles carrying links	Conditional	Lawful only where the placement is identifiable advertising in a digital publication. A paid editorial placement not identifiable as advertising is marketing through an unlisted channel. The placement, not the link, is what is assessed.
Welcome offers, free play, deposit bonuses, discounted play, bundled incentives	Prohibited	Prohibited as acquisition marketing. This is the mechanic most Finnish launch plans are built on.
Bonus play money to an established customer, communicated to that customer	Conditional	Permitted for retention where a customer relationship already exists. Moderate, equal terms, wagering requirement no higher than five times the bonus, and not tied to money or time spent gambling. Keep this row separate from the row above: a permitted retention offer placed in an advertisement is the marketing of a bonus and falls under it.
Non-gambling benefits to an established customer	Conditional	Event tickets, products or services free or discounted, provided the value is moderate and the customer relationship is established.
Earned editorial coverage the operator did not pay for or direct	Permitted	Not the operator’s marketing. Paying for it or directing it changes the assessment.
Outdoor advertising, brand level	Conditional	Permitted, geo-fenced away from schools, pharmacies, healthcare centres, rehabilitation facilities and educational institutions.
Outdoor advertising of betting or online casino products	Prohibited	Product-level outdoor is not within the section 51 permission. Events remain the exception where games may appear away from the operator’s own properties.
Email and SMS to the operator’s own list	Conditional	Prior explicit consent required and telephone calls prohibited. Excludes anyone who has set a block on all gambling, and anyone who has not played this licence holder’s games in the preceding two years. Where a block is game-specific, only the unblocked games may be marketed.
B2B marketing to operators and suppliers	Outside scope	Marketing a platform, studio, KYC, payments or data product to businesses is not marketing gambling to consumers. Reasoning, not a sourced ruling. Confirm with counsel before relying on it.

8. What is still open

Expected resolution: before the end of 2026

The Police Board is drafting marketing regulations for publication before the end of this year, reported from its own presentation at a recent Rahapeliala ry seminar. The questions below are the ones those regulations exist to answer, so they should be read as pending rather than permanently unsettled. This paper will be reissued when they publish.

Pre-market conduct

The Board has not published guidance on how marketing conducted before 1 July 2027 will be treated in a licence assessment. It remains the live regulator until 30 June 2027 and is the body that would issue it. Until it exists, the risk is real and cannot be quantified.

Where the moderation threshold sits

No figure has been published for extent, scope, visibility or frequency. It is the single largest unpriced variable in any Finnish media plan, and it is the most likely subject of the regulations due before the end of 2026.

What counts as an established customer relationship

The concept carries the whole retention bonus permission and it is not defined as simply holding an account. Counsel should settle it for the specific product before any reload offer is designed.

Equivalent digital publications

The permitted channel list includes print media and equivalent digital publications. How far that extends beyond established news and magazine titles has not been settled in guidance.

Identifiable advertising and followed links

Whether an identifiable advertisement in a digital publication may carry a followed link, and whether that changes the assessment from advertising to something else, is not addressed in the sources reviewed.

How moderation will be assessed in practice

It will be judged after publication, which places the risk on the licensee’s own record-keeping rather than on a pre-clearance process.

9. What to do in the ten months remaining

Inventory the existing Finnish footprint. Every paid placement, affiliate deal, influencer agreement and live link pointing at Finnish-language material. Most operators do not have this list and cannot produce one quickly.
Classify each item against section 7 and set a removal date. Anything prohibited from 1 July 2027 needs an agreed date before that, not a plan to review it later.
Move planned acquisition budget onto owned assets. The permitted list pushes value back to the operator’s own domain, so depth, structure and responsible gambling content built now carry across the date with nothing to retire.
Screen the CRM database against the two-year rule now. Direct marketing is limited to people who have played your own games within two years, on top of consent and block checks. Establishing whether your data even supports that query takes longer than writing the policy that depends on it.
Rewrite the content standard before commissioning any Finnish copy, and put the section 55 disclosures in the template. The content restrictions rule out the tone most casino copy uses, and a writer without a written standard will produce material that has to be discarded. Age limit, play-management tools and help for gambling problems belong in the artwork template, not in a reviewer’s checklist.
Keep the assessment record. Moderation and content compliance are judged after publication. A dated written assessment for each piece is the only evidence that the decision was considered at the time.

About FinEst Verba. FinEst Verba writes regulated-market content and documents, and translates them, for the Finnish and Estonian markets. Translation since 2005. Contracts, technical documents and marketing materials in Estonian, Finnish, English and German since June 2006. Legal translation since 2010. iGaming, crypto and trading platform terms of service and privacy policy translation since 2017. Target languages Estonian, Finnish and English, with native Finnish and Estonian; source languages also include Dutch, Russian and German.

Scope of practice. This is drafting, translation and written analysis. It is not legal advice, compliance certification or approval, and no compliance sign-off is offered. Your compliance function, responsible person or counsel reviews and approves what is delivered. Where a translation must carry legal force in Finland or Estonia that requires a state-authorised translator, which I am not, and I will say so and refer that specific document.

A written mapping of a specific operator’s or agency’s existing Finnish footprint against the permitted channel list, with each item classified and a proposed retirement date, is available as a commissioned engagement. The output is a document your compliance function uses to decide. The decision stays with them.

Sources

Rahapelilaki (Gambling Act 10/2026), Chapter 4, sections 51 to 55. The permitted channel list and the outdoor position (51), content restrictions (52), direct marketing screens and the game-specific block rule (54), and mandatory disclosures (55). The statute governs; everything below is a summary of it.
Ministry of the Interior, gambling reform questions and answers. Influencer treatment and the bonus split.
National Police Board presentation, Rahapeliala ry seminar, 2026. Applications pending above sixty, average processing time of six months, and marketing regulations in preparation for publication before the end of 2026. Reported to the author by a Finnish gambling law practitioner who attended.
Borenius, Finland’s Gambling Act Reform: A Practical Guide to the New Licensing Regime, 28 May 2026. Application opening, market launch, processing time, permitted channel list, and the operator-specific wording of the two-year direct marketing rule.
Nordic Law, Marketing in Finland’s Reformed Gambling System. Permitted channels, content restrictions, direct marketing screens, and the bonus split.
Nordic Law, Recent Developments in the Finnish Gambling Reform. Moderation standard, enforcement tools, pending National Police Board guidance.
Krogerus, Finland’s new gaming licence regime: a quick guide. Fitness and propriety criteria, disqualifying factors, current monopoly status and the prohibition on marketing before the transition date.
G3 Newswire, National Police Board confirms 50 applications for online licences, 10 June 2026. Application count, applicant origin, fee, processing target.
Poliisi, Marketing of gambling. Regulator’s own marketing guidance.

Status of this document

This is a practitioner’s reading of the marketing provisions of the Finnish Gambling Act (Rahapelilaki 10/2026) as at 15 September 2026. It is not legal advice and it does not create a lawyer relationship. Where the Act is open to more than one reading, this paper says so rather than resolving it. Operators and suppliers making a licensing or spending decision should have Finnish gambling counsel confirm the position on the specific facts.

Everything asserted here is traceable to the sources listed at the end. Where a conclusion is reasoning rather than a sourced rule, it is marked in the text.

Licensing and enforcement sit with the National Police Board until 30 June 2027 and with the Finnish Supervisory Agency (Lupa- ja valvontavirasto) from 1 July 2027.

Version history

1.5, 15 September 2026. The media price finding rewritten. Earlier versions carried a practitioner observation that increases run well beyond the publicly reported figures. The practitioner who supplied it declined attribution, so the figure is removed rather than published unsourced. The finding now rests only on the publicly reported figure, framed as a floor rather than an estimate, and is marked as reasoning.

1.4, 9 September 2026. Three updates from a Finnish gambling law partner, based on the National Police Board’s own presentation at a recent Rahapeliala ry seminar. Applications pending have risen above 60. Average processing time is now six months because of that volume, replacing the earlier three to six month range. And the Police Board is currently drafting marketing-specific regulations for publication before the end of 2026, which gives the open questions in section 8 an expected resolution date rather than an indefinite one.

1.3, 9 September 2026. Executive summary added at the front, at the suggestion of a Finnish gambling compliance officer who reviewed version 1.2 and asked for the C-level position before the detail. Five findings: the acquisition engine is gone rather than restricted; media prices are rising faster than budgets assume, a point narrowed in version 1.5; the moderation standard caps volume at the same time; a share of entrants will budget for loss to buy position; and owned, earned and brand assets are the only things that cross the date intact.

1.2, 8 September 2026. Second practitioner review together with a Finnish Compliance Specialist, this one against the statute rather than against summaries. Outdoor closed as a settled point using section 51. The two-year direct marketing rule narrowed to the operator’s own games under section 54, with the game-specific self-exclusion sentence added. Section 55 mandatory disclosures added as a new section, having been absent entirely. Affiliate and influencer wording changed from prohibited by name to excluded from the permitted-channel list, which is the accurate mechanism. Bonus section tightened on the definition of an established customer relationship and on advertised retention offers.

1.1, 8 September 2026. Bonuses corrected from a flat prohibition to the acquisition and retention split. Two-year direct marketing exclusion added. Outdoor flagged as open. Correction to the “brands only, not games” reading.

1.0, 7 September 2026. Not published.

Section references are to the Rahapelilaki (Gambling Act 10/2026), Chapter 4. They come from practitioner review against the Act and its Finnish text; readers verifying this paper should read the sections themselves rather than the summaries in the source list.

Marketing Under the Finnish Licence