GB Gambling Commission warns affiliates over under-age gamblers

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, stated 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 could be benefiting from affiliate advertising models that offer free-to-play versions of real-money games on their websites without the necessary age verification.

The Commission have warned operators that under Social Responsibility Code provision 1.1.2, that they are responsible for the actions of third parties whom are 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, where they are offering free-to-play games without the required age verification safe guards, they would be in breach of the updated license 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, it has been seen that the Commission has reiterated that the new requirements do not apply to other forms of advertising such as screenshots or videos of games that may be available on gambling affiliate websites. B2B suppliers offering free-play demo versions of the game as a way 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.

In a blog post, law firm, Wiggin said: “It will be interesting to see if marketing affiliates are able to justify the cost if introducing age verification processes which could meet the standards required by the Gambling Commission.”

The source also highlighted that some B2B providers have increasingly been acting as affiliates themselves, placing them in something of a grey area.

The UKGC letter stated: “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.”

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