Affiliate marketing — in which third-party publishers and content producers refer players to iGaming operators in exchange for a commission, typically based on deposited players or revenue share — has been a primary player acquisition channel for online gambling operators globally for more than two decades. In Ontario's regulated market, affiliate marketing operates within a detailed regulatory framework established by AGCO's Registrar's Standards for Internet Gaming and its Advertising and Marketing Standards for Internet Gaming, which jointly impose obligations on both the registered operators and the affiliate partners they use.
AGCO's Accountability Framework for Affiliates
The foundational principle of AGCO's approach to affiliate marketing is that registered operators bear regulatory accountability for the conduct of their affiliate partners. An operator cannot disclaim responsibility for content produced by an affiliate by arguing that the affiliate is an independent third party. Standard 2.3 of AGCO's Internet Gaming Standards requires that operators ensure all marketing and advertising conducted on their behalf — including by affiliates — complies with AGCO's advertising standards.
This accountability structure has significant practical implications. Operators must contractually bind their affiliates to compliance with Ontario-specific advertising requirements, monitor affiliate content for compliance, and take corrective action when violations occur. The failure to manage affiliate compliance is itself a compliance failure by the operator, which has incentivized operators to implement affiliate auditing programs and to terminate relationships with affiliates who repeatedly produce non-compliant content.
Key Advertising Standards for Affiliates
AGCO's advertising standards for Ontario iGaming are detailed and prescriptive in several key areas. The prohibition on targeting minors applies fully to affiliate content: affiliate websites and marketing materials must not be designed to appeal primarily to persons under 19, must not use imagery or themes associated with children or youth culture, and must implement age-gating mechanisms where appropriate.
Bonus and promotion advertising is a category of particular regulatory focus. Affiliates who publish promotional content about operator welcome bonuses, free spin offers, or deposit match promotions must include the material terms and conditions of those promotions — including wagering requirements, time limits, and game restrictions — with equal prominence to the headline promotional claim. AGCO has taken the position that promotions advertised without clear and prominent disclosure of conditions violate the misleading advertising provisions of the standards, regardless of whether the full terms are accessible via a hyperlink.
Celebrity and athlete endorsements, both by operators and their affiliates, are restricted under Ontario's standards. Marketing that features active professional athletes in contexts that could suggest those athletes personally endorse gambling, or that uses athlete imagery in ways that could appeal disproportionately to young fans, is prohibited. This restriction has affected a significant number of affiliate-produced content pieces that featured sports team branding or player imagery.
Responsible Gambling Messaging Requirements
All advertising and marketing content relating to Ontario iGaming operators — including affiliate content — must incorporate responsible gambling messaging in accordance with AGCO's specified requirements. At minimum, content must include a reference to the operator's responsible gambling tools or to a relevant responsible gambling resource such as ConnexOntario. The messaging must be legible and not designed to minimize its prominence relative to promotional content.
AGCO has issued guidance clarifying that responsible gambling messaging that is technically present but structured to minimize its visual prominence — such as very small font, low contrast against the background, or positioning that requires significant scrolling to reach — may not satisfy the standard's intent. Affiliates operating in Ontario have had to review their content templates and layouts to ensure compliance with the spirit as well as the letter of the messaging requirements.
Editorial Independence and Disclosure Requirements
A significant portion of iGaming affiliate activity takes the form of editorial-style content — reviews of operators, comparisons of betting platforms, guides to games and strategies — that generates referral traffic through search engine optimization. AGCO's standards require that content of this type clearly discloses any commercial relationship between the publisher and the operators reviewed or recommended.
The disclosure requirement applies to revenue-share arrangements, cost-per-acquisition deals, and any other form of consideration received for publishing content that includes referral links to licensed operators. Content that presents itself as independent editorial while concealing a commercial referral relationship violates the disclosure standards. This requirement mirrors the disclosure rules applied by the Competition Bureau under Canada's Competition Act to influencer and sponsored content more broadly.
Enforcement Actions Against Affiliate Non-Compliance
AGCO has taken enforcement action against operators whose affiliates produced non-compliant content in the period since the Ontario market launch. The enforcement activity has focused primarily on advertising standards violations including inadequate bonus disclosure, missing responsible gambling messaging, and unauthorized use of athlete imagery in affiliate-published material. Operators receiving compliance notifications related to affiliate conduct have in several cases terminated their affiliate relationships with the non-compliant publishers and implemented enhanced monitoring programs.
AGCO does not currently register affiliates as regulated entities in their own right — unlike the approach taken by some European regulators such as the UK Gambling Commission, which has introduced affiliate registration requirements. The AGCO approach relies on the operator-accountability principle to ensure compliance throughout the affiliate marketing chain. Industry participants have noted that direct affiliate registration could provide additional regulatory leverage but would also increase the administrative burden on the hundreds of individual publishers that participate in Ontario's affiliate marketing ecosystem.
The Grey Affiliate Market
A parallel challenge in Ontario's affiliate market is the presence of affiliate publishers who promote offshore operators — operators that are not registered with iGaming Ontario and whose offerings to Ontario residents are technically unauthorized. These affiliates are not subject to AGCO's oversight since they have no contractual relationship with a registered operator. AGCO has noted this grey-market affiliate activity as a continuing concern and has taken steps to engage with major search platforms and advertising networks to reduce the visibility of non-compliant operator promotions in search results targeting Ontario audiences.