Gambling Commission issues affiliate warning over free-to-play games

21 June 2019

The GB Gambling Commission has written to operators reminding them to ensure that affiliate partners are not offering free-to-play games without age verification controls in place.

The Commission's Licence Conditions and Codes of Practice (LCCP), which were updated on May 7, state that remote licensees may only allow players to access such products after they have verified they are over the age of 18.

In the letter seen by, the regulator said it had been made aware licensees may be benefitting from affiliate advertising models that offer free-to-play versions of real-money games on their websites without the necessary age verification.

The Commission warned operators that under Social Responsibility Code provision 1.1.2, they are responsible for the actions of third parties contracted to support their activities in the market. These third parties, according to the LCCP, must “conduct themselves in so far as they carry out activities on behalf of the licensee as if they were bound by the same licence conditions and subject to the same codes of practice as the licensee”.

As such, any operator taking traffic from an affiliate offering free-to-play games without age verification safeguards would be in breach of the updated licence conditions. 

“You should take steps immediately to ensure that your free-to-play games cannot be accessed by children and young people via affiliate’s websites,” the letter said.

However, the Commission has reiterated that the new requirements do not apply to other forms of advertising such as screenshots or videos of games that might be available on gambling affiliate websites. B2B suppliers offering free-play demo versions of games in order to advertise them to commercial third parties, rather than consumers, are also unaffected.

The Commission’s letter comes after Clive Hawkswood, chair of Responsible Affiliates in Gambling, earlier this month told that one of the industry association's first acts would be to open discussions with affiliates over the use of free-to-play games to drive traffic.

Hawkswood, who previously led the Remote Gambling Association, noted that such games appearing on affilitate sites had been flagged as a concern by the regulator.