German affiliates searching for answers as Google updates ad policy

Another month, another announcement from Google. This time, it’s German affiliates that find themselves in the spotlight after the search giant updated its gambling and games policy. Affiliate Leaders takes a look at how the new restrictions will radically change the advertising landscape.

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At the end of last month, Google announced new plans to restrict the promotion of gambling services from companies not licensed by the Gemeinsame Glücksspielbehörde der Länder, or more simply known as GGL.

From 25 September, any gambling company looking to advertise its website will require a GGL licence in order to apply for a certification of approval from the search engine. The change is expected to impact all companies that “offer gambling aggregation services, for example by linking to multiple offers from different operators on their landing page”.

In short, affiliate websites are going to feel the impact of the policy update, which is expected to encompass both Google search and display ads.

Why is Google doing this? 

Google’s announcement forms part of the search engine’s commitment to make a clear distinction between licensed and unlicensed operators. As it stands, its policy reads: “We support responsible gambling advertising, and we comply with local gambling laws and industry standards, so we do not allow certain types of gambling advertising. 

“Gambling ads are allowed if they follow the policies below and the advertiser has received the appropriate Google Ads certification. Gambling ads must target approved countries, have a landing page that displays responsible gambling information, and never target minors. Check local regulations for the areas you want to reach.”

That may seem comprehensive enough to allow the dominant search advertising business to reject any ads from the black market, but Google has come under increasing pressure in recent years for not doing enough to combat the efforts of illegal operators looking to acquire customers in regulated markets. One notorious example of it appearing to be lax in the implementation of its rules was the promotion of websites offering links to “non-GamStop casinos” in the UK.

So it is easy to understand why it has decided to tighten up its policies in Germany, where the black market has become the battleground for a dispute between operators and the authorities. 

A growing number of players are believed to be using sites that are not regulated by the GGL. In fact, a study conducted by Günther Schnabl of the University of Leipzig in November 2023 identified a significant shift towards unlicensed operators since January 2019, with 28.9% directed towards EU operators, and a further 19.9% to offshore gambling companies.

The study also estimated that three-quarters of online revenue was generated by black market sites. The regulator disputes those figures, but it is in the interests of all parties in the regulated market to halt the trend and, ultimately, ensure the steady flow of tax revenues to the state. 

Impact on affiliates

As with any market, affiliates have played a key role in the development of the gambling sector in Germany, providing an effective platform for operators to acquire customers and drive new traffic to their platforms. 

That situation should continue, despite the update to Google’s policies. However, it will continue with one very important difference – affiliates will have to choose between benefiting from the visibility provided by Google’s PPC ads and potentially lucrative partnerships with unlicensed operators. 

The effective removal of Google ads from affiliates who wish to offer what might be termed ‘whole of market coverage’ is likely to make other channels more competitive, with an even greater focus being placed on organic traffic, and earning and then defending those all important first-page rankings. That may, in turn, require greater investment in new technologies and more sophisticated targeting strategies.

The alternative narrative is that the change could push German-facing affiliates to become more selective about which partners they collaborate with and to place a greater emphasis on consumer protection. It could cause them to be more mindful of how they market gambling products, ensuring that their campaigns are not inadvertently targeting at-risk individuals.

Of course, the best affiliates already understand the importance of responsible gambling messaging, both for players and for their ability to build sustainable long-term businesses. Will Google’s new policy change the attitude of those looking to make a quick buck? Probably not. 

Either way, it’s safe to say that affiliates operating in Germany are facing a radically different landscape to what they’ve been used to.

New opportunities

The situation might sound as doom-and-gloom laden as a Kier Starmer speech right now, but there are opportunities hidden in and among these new protocols. However, these will only be evident to those affiliates with the ability to adapt.

The affiliates that take the initiative to invest in compliance and pivot their marketing strategies in accordance with Google’s updated advertising policy will be well-placed to succeed in Germany.

Ultimately, these changes form part of Google’s broader strategy to promote a regulated, responsible gambling industry. For affiliates, understanding and adapting to these new measures will be crucial to maintaining a presence in what could well be a highly-lucrative market.