Summary: In Great Britain the operator answers for its affiliates. Gambling Commission licence condition 1.1.2 makes licensees responsible for the third parties they contract with and requires contracts that let them end the deal if an affiliate breaches an advertising code, and the CAP Code applies to affiliate marketing done on an advertiser's behalf. Basher Agency builds and runs affiliate programmes for UKGC-licensed operators, and runs its own affiliate sites as a SiGMA Top 50 ranked affiliate. Sources: Gambling Commission LCCP and guidance, ASA, checked 5 November 2026.
What does an iGaming affiliate agency do for a UK operator?
An iGaming affiliate agency recruits the comparison sites, tipsters, streamers and media buyers that send players to a casino or sportsbook, negotiates their deals, checks that the tracking is right and makes sure what they publish would pass a regulator's review. For a UK operator the last part carries the most weight, because affiliates are not licensed by the Gambling Commission but the operator is, and the Commission holds the operator accountable for them.
So a UK affiliate programme is two jobs at once: an acquisition channel that has to pay back on depositing players, and a compliance perimeter around dozens or hundreds of independent publishers.
Who is responsible when a UK affiliate breaks the rules?
The operator. The rules come from two regulators, and both point back to the licence holder.
| Source | What it says about affiliates |
|---|---|
| LCCP 1.1.2, responsibility for third parties | Licensees are responsible for the actions of third parties they contract with. Contracts must require the third party to act as if bound by the licence conditions and codes, to supply information the licensee needs for its regulatory returns, and must let the licensee end the contract promptly for a breach, including an affiliate breaching a relevant advertising code |
| Gambling Commission guidance on affiliates and third parties | Affiliates doing email or SMS marketing for an operator fall under the LCCP, the Data Protection Act 2018 and PECR. The Commission and the ICO see the operator as primarily responsible for breaches. Operators must take reasonable steps so affiliates do not market to self-excluded people |
| CAP Code section 16 | The gambling advertising rules cover marketing by third parties, for example affiliate marketers, acting on an advertiser's behalf |
One line in the Commission's guidance deserves attention from anyone running a large affiliate base: a single point of failure, such as one staff error, is unlikely to count as having taken reasonable steps to stop marketing reaching self-excluded customers. A clause in the affiliate terms is not enough on its own. You need a process that checks it.
What has changed for UK affiliate offers since January 2026?
Bonus copy. Since 19 January 2026 the Gambling Commission limits bonus wagering requirements to 10 times and bans offers that require play on two or more product types, such as betting and casino together (Gambling Commission, 26 March 2025). Affiliate sites often keep old bonus tables for months. Every UK offer an affiliate shows for your brand has to match the terms you actually run, and under 1.1.2 a stale 35x welcome offer on an affiliate page is your problem.
For a review site, the change also moves the comparison. Headline bonus size matters less when every UK offer sits under the same cap, and terms, payment speed and licence status matter more.
How does Basher build a UK affiliate programme?
Basher Agency works on the operator side of the deal, and we know the other side because we run affiliate sites ourselves. Our consumer site, for example, compares UKGC-licensed online casinos and checks each one against the Gambling Commission public register.
- Programme audit. We review your deal book, tracking set-up, how concentrated your FTDs are among the top affiliates, and where fraud and compliance exposure sits. For the UK that includes whether your affiliate terms carry the 1.1.2 clauses and how self-exclusion suppression reaches affiliates who email or text.
- Deals and contracts. CPA, revenue share and hybrid deals negotiated against real player value, with termination rights for advertising code breaches written in, as 1.1.2 requires.
- Recruitment. A target list of UK publishers by vertical (casino comparison, racing and football tipsters, bingo, streamers), then outreach, onboarding and a creative kit that already meets CAP section 16 and the current bonus rules.
- Monitoring and payments. Regular checks of affiliate pages for outdated offers, under-25 imagery and youth-appeal content, plus monthly cohort reporting, reconciliation and payments.
How affiliate returns vary by deal type is covered in our iGaming affiliate ROAS benchmarks, and whether to build the team in house or hire an agency is in our in-house team vs agency comparison.
Which operators is this for?
UK affiliate management with Basher is for casino, sportsbook and bingo brands holding a Gambling Commission remote licence. It fits operators launching a UK programme from zero, and operators with an existing programme that has grown faster than their ability to monitor it.
We do not run affiliate programmes for brands that target UK players without a UKGC licence. The broader view of the British market, including channels and the regulator, is on our United Kingdom market page.
FAQs
Are affiliates licensed by the UK Gambling Commission?
No. Affiliates do not hold Gambling Commission licences for their marketing work. The Commission regulates them through the operator: licence condition 1.1.2 makes the licensee responsible for the third parties it contracts with and requires contract terms that bind them to the same standards. Source: LCCP 1.1.2, checked 5 November 2026.
Does the CAP Code apply to casino affiliate websites?
Yes, when the affiliate is marketing on the operator's behalf. Section 16 of the CAP Code states that its gambling rules cover marketing by third parties such as affiliate marketers acting for an advertiser. The ASA enforces it. Source: CAP Code section 16, checked 5 November 2026.
What must a UK affiliate contract include?
Under LCCP 1.1.2 the contract must require the affiliate to act as if bound by the licence conditions and codes of practice, to give the operator the information it needs for its reporting to the Commission, and must allow the operator to end the contract promptly if the affiliate breaches it or a relevant advertising code.
Can affiliates send email or SMS offers for a UK operator?
Yes, but the operator carries the risk. The Gambling Commission guidance says affiliate email and SMS marketing falls under the LCCP, the Data Protection Act 2018 and PECR, that the operator is primarily responsible for breaches, and that affiliates must remove self-excluded people from their lists. Source: Gambling Commission guidance, checked 5 November 2026.
What is casino affiliate marketing?
Casino affiliate marketing is paying independent publishers, usually per depositing player (CPA), as a share of net revenue (revenue share) or both, for players they refer to a casino. In the UK the casino operator is responsible for what those publishers say about its brand and offers.
Is Basher an affiliate or an agency?
Both. Basher Agency manages affiliate programmes for licensed operators and also runs its own affiliate properties, which are ranked in SiGMA's Top 50 affiliates. That is why our deal negotiation and monitoring are built from the publisher's side as well as the operator's.
Talk to us about your UK affiliate programme
If you hold a UKGC licence and want your affiliate programme audited, rebuilt or run day to day, send us a brief through the contact form. Tell us your products, current affiliate count and tracking platform, and we will reply with how we would approach it.