A body to raise standards may also be raising the barriers to entry.
Those who have been following the gambling affiliate sector for more than two minutes will have had a moment of deja vu around the news of the launch of the Responsible Gambling Affiliate Association last week.
The RGAA has been founded by the six major U.S. gambling affiliates and, trumpeted the press release, will “serve as a trade association to advocate for reasonable regulation, responsible advertising, and consumer protection”.
Those affiliates just happen to be the biggest in the market: Better Collective, Catena Media, Gambling.com Group, Oddschecker Global Media, Spotlight Sports Group, and XLMedia.
Not by coincidence, they all have their roots in the European gaming sector. Four are listed, three in Scandinavia, one in the UK and all have significant skin in the game when it comes to the U.S. gambling affiliate space.
But for those keen on visual double stakes, here comes the punchline. Three of the six – Better Collective, Oddschecker and Spotlight Sports Group – are also the founding members of the Responsible Affiliates in Gambling organisation formed over four years ago.
Like with RGAA, the original press release for RAIG suggested its purpose was to “social responsibility within the affiliate marketing sector to create a safer environment for online users, with the hope that the association will grow, and other like-minded companies will join in due course”.
Needless to say, none have. Indeed, one could be forgiven for thinking RAIG has been in hibernation for much of the past four years, pandemic and all. According to its own website, the body’s last press release was sent in January 2021 when it said the association “welcomes the Gambling Act Review”. Since then, nothing.
In that time, of course, we have – finally – got sight of that Gambling Act Review White Paper at which point the government and the UK Gambling Commission made clear by omission that they had no intention of regulating the gambling affiliate space.
More hassle than it’s worth
Previous to finding out the sector would be ignored by the authorities, RAIG had suggested in a separate press release in June 2020 that “following a thorough internal review”, it had decided it would “support in principle the introduction of a statutory licensing or registration regime for affiliates who are active in the British gambling market, subject to the detail of any proposed system and the clear identification of the benefits that it would provide to consumers”.
Such a system of oversight might now have occurred in the UK, but in the U.S. it is a different matter. There, licensing, particularly if revenue share is involved, is a prerequisite for getting involved in the gambling affiliate business in many of the OSB and iCasino states.
The RGAA press release suggests the motives for its formation lie beyond the question of regulation, and looks instead to wider standards of commercial behaviour.
“Although gambling affiliates are subject to significant regulation, there is potential for further improvement in elevating the standards of the affiliate marketing sector,” it suggests.
To achieve this aim, the RGAA puts forward six areas which it says are “strategic pillars”. Namely the promotion of competitive gambling markets, industry education, consumer protection, empowerment and choice, advertising codes of conduct and responsible business practice.
No one could truly argue against any of those. But at the same time, it is still possible to suggest that such a list of aims is very much self-serving.
After all, the ‘promotion of competitive gambling markets’ is effectively special pleading on the part of affiliates who know that limited competition in any given state leads to less opportunity for the affiliates.
But more than that, the fact that the companies involved in setting up the RGAA are at the very top of the tree in terms of affiliate organisations gives the impression of a body designed to erect barriers to entry with the sector.
The areas covered by the pillars are, for the biggest affiliates, the cost of doing business. Coming from Europe, they understand that they are already investing in such efforts. Their combined businesses are already carrying such overheads involved in meeting such standards.
By positioning the RGAA as the body for compliant and responsible affiliates and aligning their aims with those of the operators, it paints the biggest affiliates as the perfect partners. And by omission, suggests something different about the smaller providers.
For obvious reasons, the founders behind the RGAA might not call the grouping a cartel. The word has connotations. But if it looks like a duck…