Most “independent” casino review sites are paid by the operators they rank, usually per depositing player they refer or as a share of that player’s losses over time. Regulators on both sides of the Atlantic — the UK’s Competition and Markets Authority, the US Federal Trade Commission, and the UK Gambling Commission — have all published rules in the past three years specifically because undisclosed commission arrangements distort what looks like neutral consumer advice. This article breaks down how the commission model works, what the enforcement record shows, and why a human-written “top 10 casinos” list is structurally harder to trust than a rankings method that never earns commission from any listed operator.
Key takeaways
- Casino affiliates are typically paid per first-time depositor (CPA) or as a lifetime share of a player’s net losses (RevShare), with RevShare deals for casino verticals reported as high as 60% of net gaming revenue.
- Under RevShare, an affiliate’s income rises when referred players lose more, which creates a financial interest that is not automatically aligned with the reader’s interest in finding a safe, fair operator.
- The UK Gambling Commission has held operators directly liable for affiliate marketing content since 2018, and the CMA can now fine businesses up to 10% of global turnover for undisclosed incentivised or fake reviews under the Digital Markets, Competition and Consumers Act 2024.
- The FTC’s 2023 Endorsement Guides update requires that affiliate-link disclosures appear in the same location and format as the endorsement itself — a “click for more” disclaimer is no longer considered sufficient.
- GamblScout.com’s rankings are generated by scoring scraped and reported operator data; the algorithm does not receive commission tied to the ranking outcome of any single operator.
Table of contents
How the commission model works
Casino affiliate programs pay in three main structures. Cost-per-acquisition (CPA) pays a flat, one-time fee once a referred player completes a qualifying action, usually a first deposit.
The CPA model implies that the affiliate receives a one-time payment when a player they linked accomplishes an agreed-upon action on the casino website, such as making first-time deposits, simply registering, or placing bets, usually ranging somewhere between $50-250.
Industry sources describing standard iGaming deal terms put
RevShare in iGaming casino at 20% to 45% of net gaming revenue, depending on partner tier, player volume, and deal negotiation history
, and one industry breakdown of commission structures reports that
for sportsbooks, iGaming affiliate RevShare percentage range could be from 15% to 40%, whereas casinos and pokers can go up to 60%
.
A third structure, hybrid, combines both:
a set CPA rate with a portion of the operator’s revenue from driven players through a RevShare model, where the affiliate receives payment when a user registers or deposits, and it doesn’t stop there
. Under this model the affiliate is paid twice for the same referred player — once on signup, then again for as long as that player keeps depositing.
| Model | How it pays | Reported range | Who bears the risk |
|---|---|---|---|
| CPA | One-off fee per qualifying depositor | Roughly $50–$250 per player | Operator pays regardless of player outcome |
| RevShare | Percentage of player’s net losses, ongoing | 15%–60% of NGR depending on vertical | Affiliate earns more the longer/harder a player loses |
| Hybrid | Fixed fee plus ongoing percentage | Combines both structures above | Shared, front-loaded toward the affiliate |
Why commission structures bias rankings
The mechanics of RevShare matter more than the headline percentage. Because the affiliate’s payment is a share of net gaming revenue, its income is tied to how much a referred player deposits and loses, not to whether that player had a safe, well-supported experience. One industry guide aimed at operators even flags the reverse risk to the operator side of the deal:
high-volume negative carry, where if a referred player wins big, the operator may pay no commission for that period
. Flip that around and the incentive for the affiliate is clear — a site paid on RevShare has a direct financial reason to prefer operators, games, and bonus structures that keep players depositing and losing over long periods, since that is what maximizes lifetime revenue share.
This is not a hypothetical conflict of interest; it is the entire economic basis of the affiliate channel. A review site that ranks operator A above operator B because A pays a higher RevShare percentage, faster payment terms, or a larger CPA is optimizing for its own revenue, and there is no requirement that this ranking correlate with lower house edges, faster withdrawals, or better dispute resolution for the player. Our scoring system and algorithmic weights hub explains the alternative: a fixed, published set of criteria that does not vary by commission offered.
The disclosure problem
Regulators require affiliates to disclose financial relationships, but the bar for what counts as adequate disclosure has been rising. The FTC’s updated Endorsement Guides make clear that
the disclosure of material connections between an endorser and the advertiser must be unavoidable, and advertisers can no longer rely solely on a “click for more” link, a general disclosure in fine print, or a disclosure in an influencer profile
. The FTC’s own guidance adds that a workable disclosure looks like
saying something like “I get commissions for purchases made through links in this post,” and in some instances a single disclosure embedded in the review may be adequate
— but a general “affiliate site” label somewhere on the page is not.
In the UK, the problem has moved from guidance to statute.
In April 2025, several practices relating to online reviews became “banned practices” under the Digital Markets, Competition and Consumers Act 2024, meaning they are automatically deemed unfair and illegal
. The CMA’s own guidance on the Act states that it
covers fake reviews, concealed incentivised reviews, and requires traders not to publish consumer reviews in a misleading way, and that traders publishing reviews must also take steps to prevent the publication of fake reviews and reviews where incentives are hidden
. Enforcement followed quickly:
in January 2025, Google signed undertakings committing to enhanced processes to tackle fake reviews, and the CMA also swept more than 100 review publishers
, before
opening a series of new investigations into fake and misleading reviews on 27 March 2026 — the first formal fake reviews cases brought under the Act
. Under the same law,
the CMA has the power to impose penalties up to 10% of global turnover in each case
. Regulators care about this because the volume of decisions built on reviews is enormous:
research from Which? found that 89% of people use reviews when researching a product or service, making it essential that the information they rely on is genuine and transparent
.
In the US, the FTC’s parallel rule closed a related gap.
On August 14, 2024, the Federal Trade Commission issued a final rule that prohibits publishing or trading in fake or misleading consumer reviews and testimonials, or engaging in other related deceptive promotional practices, and the rule permits the FTC to seek civil penalties against knowing violators.
Neither rule is gambling-specific, but both apply directly to casino “best of” lists, because a numbered ranking with a star rating and a “read our review” button is exactly the format both regulators are scrutinizing.
Who regulators actually punish
In UK gambling specifically, liability for affiliate content sits with the licensed operator, not the affiliate.
In October 2018, the UK Gambling Commission introduced changes to LCCP to strengthen requirements in key areas and clarified its position that operators are responsible for the actions of their third parties, including marketing affiliates.
The same enforcement report notes that the Commission
elevated compliance with the UK Advertising Codes to a social responsibility code, meaning operators that breached any aspect of the Codes could be subject to the full range of its regulatory powers, including financial penalties.
A trade-body scoping paper on the subject confirms the structure:
affiliate advertisers are not directly regulated, but their activity is the responsibility of licensed UK operators who are accountable to the Gambling Commission and Advertising Standards Authority for advertising conducted on their behalf, under a code that requires adverts to be socially responsible, obviously identifiable, and that any conditions on product offers are clear and understandable.
This liability structure has a practical consequence for readers: operators, facing regulatory exposure for whatever their affiliates publish, have terminated relationships en masse rather than police every page. One written submission to a UK parliamentary committee on the subject records that
the Commission’s compliance policy has led to thousands of affiliate relationships being terminated because operators could no longer be satisfied that some of the affiliates they were working with were sufficiently compliant.
That is a sign the compliance problem is real and widespread, not a one-off. It also means an affiliate site’s list of “trusted” operators can change overnight for compliance reasons that have nothing to do with the operator’s actual quality — a dynamic our licensing and jurisdictions coverage tracks separately from commission questions.
Spotting a commission-driven review
A few patterns are common enough to be useful checks for readers:
- Ranking order that tracks bonus size. If the “#1” operator changes seasonally in step with which brand is currently running the largest welcome offer, that is consistent with a CPA deal, not a stable scoring method.
- Vague or buried disclosure. Under current FTC guidance, a disclosure has to sit in the same place and format as the endorsement itself; a footer link or an “affiliate disclosure” page reached by a separate click does not meet that bar per the same guidance discussed above.
- No visible negative findings. Human-written reviews that never surface a slow withdrawal, a restrictive wagering term, or a complaint pattern are difficult to reconcile with real operator data, since payout speed and dispute volume vary measurably across the market.
- Star ratings without a published formula. A “9.2/10” that cannot be reproduced from stated inputs is not verifiable, and the CMA’s review guidance explicitly targets misleading aggregated review summaries as a banned practice.
What an algorithmic approach changes
None of this means every human-written review is dishonest, and it does not mean automated scoring is immune to bad inputs. What it does mean is that a review site paid by RevShare has an ongoing, structural incentive that a fixed scoring model does not: the human writer’s income rises with player losses at the operator they are reviewing, while a rules-based score applied uniformly across operators has no equivalent mechanism. GamblScout.com’s approach — detailed across our hubs on data scraping and the technical engine, NLP and sentiment analysis, and security, fraud detection and fair play — pulls the same categories of data (licensing status, payout speed, complaint volume, bonus terms) for every operator scored, using the same published weights regardless of whether that operator runs an affiliate program with us at all.
This does not make the output infallible; scraped data can be incomplete, and scoring weights themselves involve editorial judgment about what matters, which is why we publish that methodology separately in our Our Core Principles & The Problem with “Human” Reviews hub. But it removes the specific conflict this article describes: no single operator’s ranking outcome changes our revenue per depositing player it sends us.
Frequently asked questions
Do all casino review sites take commission?
The overwhelming majority of “best casino” and “top 10” content on the open web is published by sites enrolled in operator affiliate programs, typically paid via CPA, RevShare, or a hybrid of the two. Disclosure of this relationship is legally required in the UK and US, but the required disclosure format has tightened substantially since 2023–2024, and older, vaguer disclosures may no longer meet current rules.
Is RevShare worse than CPA for bias?
RevShare creates a more persistent conflict because the affiliate’s income scales with a player’s losses over the player’s lifetime, whereas CPA is a one-time payment unaffected by how the player subsequently fares.
RevShare rates for casino verticals have been reported as high as 60%
, which is a meaningful ongoing share of one operator’s revenue from one reader’s losses.
What happens if a review site doesn’t disclose commission?
In the UK, undisclosed incentivized content can fall under banned practices in the Digital Markets, Competition and Consumers Act 2024, exposing the publisher to CMA enforcement with fines of up to 10% of global turnover. In the US, the FTC treats non-disclosure of affiliate links as a potential violation of Section 5 of the FTC Act.
Can an algorithm be biased too?
Yes — any scoring system reflects the weights its designers chose, and those weights should be published and open to scrutiny. The distinction we draw is not “algorithm good, human bad” but “commission-linked incentive versus none”; an algorithm that is paid per depositing player it refers would have the same structural problem described in this article.
Methodology note
GamblScout.com’s algorithm scores operators using scraped licensing data, published payout-speed statistics, complaint-forum sentiment analysis, and bonus-term text extraction, applied identically across every operator in a given category regardless of commercial relationship. Weights for each input are published on our scoring system and algorithmic weights hub, and the underlying collection methods are described on our data scraping hub.
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