Affiliates deserve a seat at the table

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Martyn Hannah, co-founder and managing director of Comparasino, emphasizes the importance of including affiliates in European regulatory discussions regarding gambling practices.

In the evolving landscape of online gambling, affiliate comparison sites serve as pivotal pillars within the regulated market ecosystem. Yet, their contributions are frequently overlooked in regulatory discussions, with some jurisdictions, such as Finland, even contemplating outright bans on these platforms.

This exclusion is perplexing given that comparison sites are instrumental in educating players about responsible gambling practices and guiding them toward reputable brands. As primary traffic drivers for licensed online casinos, affiliates play a vital role in sustaining a healthy gaming environment.

For many users, comparison sites represent the initial resource for discovering online casinos, thereby becoming essential tools for operators in their customer acquisition strategies. Eradicating affiliates from the marketplace removes a critical liaison for player education and undermines efforts to direct users toward licensed operators—a vital reminder that many players remain unaware of the licensing requirements governing online casinos.

Driving Channelisation and Regulatory Compliance

Even in markets where affiliates can operate, channelisation remains a significant concern. Sweden and the Netherlands, for example, have observed channelisation rates falling well below expectations. The question arises: why eliminate a channel that can effectively guide players towards licensed operators?

Despite not being formally included in regulatory dialogues, affiliates can positively influence channelisation. The potential impact of integrating affiliate insights into regulatory frameworks could be transformative, leveraging our industry knowledge to strengthen market compliance.

The relegation of comparison sites from discussions on regulation appears rooted in a pervasive negative perception. This bias likely arises from the unfavorable actions of a minority of affiliates over the years. Unfortunately, even today, certain sites target self-excluded players and promote unlicensed brands. While such behavior is both abhorrent and alarmingly common, it’s critical not to generalize about the entire affiliate ecosystem. The UK, for instance, hosts a spectrum of reputable comparison sites, ranging from publicly traded giants to dedicated independents committed to player welfare and industry integrity.

At Comparasino, we aspire to engage in constructive conversations on responsible gambling, understand current market challenges, capture player preferences, and contribute to the shaping of equitable regulatory frameworks.

The Essential Need for Affiliate Representation

The absence of an affiliate voice in regulatory discussions curtails our ability to share valuable insights about the potential repercussions of regulatory changes on the market. Furthermore, we lack the platform to express what practices are effective and to propose actionable improvements.

Regulators are understandably apprehensive about the burgeoning black market, striving to forge a balance between player protection and the operational viability of online casinos. Failing to achieve this balance may drive players toward unlicensed alternatives.

A prime example of this imbalance can be observed in the UK market, where operators are hesitant to offer competitive welcome bonuses. Excessive caution has led to a homogenization of promotional offers, typically limited to a standard 100% deposit match and a handful of free spins.

The Challenge of Limited Bonus Offers

The scarcity of attractive bonus options naturally entices players toward unlicensed operators who flaunt offers of 500% matches and generous free spins. The reality is that many players may not grasp the critical importance of licensing in their gambling decisions.

The core issue is not the bonuses themselves but the associated wagering requirements, which can inadvertently encourage players to gamble beyond their means. A pragmatic solution would be to either limit or eliminate such requirements. Observing a surge in demand for no- and low-wagering casinos, brands like PlayOJO and Heart Bingo are already differentiating themselves in this regard by offering accessible promotions that appeal to player sensibilities.

This approach not only enhances consumer choice but also aligns with more responsible industry practices, thus benefiting all stakeholders, including comparison sites like ours.

Equal Standards for All Participants

In light of increased regulatory scrutiny, affiliates are now subject to stringent marketing regulations similar to those imposed on operators. At Comparasino, we view ourselves as brands in our own right and actively engage in marketing to boost awareness of our services.

Historically, our marketing focus was predominantly on search engine optimization; however, we now embrace a diverse strategy that includes paid media and out-of-home advertising, such as radio and billboards. We conduct thorough research prior to launching any marketing initiatives to ensure compliance with existing regulations, but ambiguity often exists regarding how these rules apply to affiliates.

While reputable affiliates are committed to adhering to these guidelines, the lack of clarity about regulations specific to our operations poses substantial challenges.

Confronting Regulatory Pressures

Heightened regulations have resulted in financial strain across global markets, impacting all stakeholders involved. For instance, the Netherlands has seen significant exits from the market as operators retreat due to escalating tax rates and new deposit restrictions.

Affiliates, as intermediaries, also face mounting pressures. The commercial deals we rely on are increasingly volatile, and as operational costs rise, some affiliates may confront a moral dilemma: should they continue directing players to licensed operators or pursue unlicensed sites with more lucrative affiliate agreements?

This predicament could lead some comparison sites to compromise their ethical standards to sustain their operations, although it is not a course that any of us advocate—for the benefit of affiliates, operators, and regulators alike.

A Collaborative Path Forward

To foster a healthier regulatory environment, it is critical to involve affiliate operators in the regulatory dialogue. Establishing a dedicated trade body that advocates for affiliate interests could pave the way for productive discussions and influence the shaping of equitable policies.

As we conclude this discussion, I pose a question to regulators: are you inclined to incorporate affiliate perspectives into your deliberations? Additionally, to fellow operators, would you support the formation of an organization aimed at ensuring our collective voice is heard?

The opportunity for collaboration is ripe; let us explore this together.

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