Key Moments:
- Norsk Tipping reported NOK 521 million in total commissions to resellers in 2024, with NOK 200 million directed to digital partners.
- The operator stayed within the official NOK 180 million annual advertising cap, but commissions to media partners are not included in this limit.
- Lotteritilsynet raised concerns about whether these commission arrangements should be treated as marketing costs rather than sales expenses.
Ad Spend Limits and Commission Contracts
Norsk Tipping has adhered to Norway’s strict cap on gambling advertising spend, limiting annual outlays to NOK 180 million as required by Lotteritilsynet in 2024. The operator’s financial records confirm compliance with this constraint. However, this cap does not account for “commissionaire agreements,” special arrangements with leading Norwegian media groups such as VG, Dagbladet, Nettavisen, and TV 2, through which these outlets earn a percentage of gaming turnover originating from their online platforms.
Commission Payments Far Exceed Advertising Budget
The company’s 2024 annual report details NOK 521 million dispersed in total reseller commissions. Of this, approximately NOK 200 million flowed to its digital media partners. Investigations show that these commissions can represent as much as 7% of turnover, highlighting the significance of these payments when compared to the traditional advertising budget.
| Category | Amount in NOK (2024) |
|---|---|
| Advertising Cap | 180 million |
| Total Commissions to Resellers | 521 million |
| Commissions to Digital Partners | 200 million |
Affiliate-Like Incentives Raise Concerns
This commission structure presents a dynamic where media companies are incentivized to promote Norsk Tipping content more aggressively, as their compensation is tied directly to the volume of player activity—paralleling affiliate marketing practices found in the broader iGaming sector. Notably, Norwegian officials have previously criticized such models when employed by foreign operators.
Regulators and Stakeholders Respond
Lotteritilsynet addressed these concerns by stating: “We see that Norsk Tipping’s commissionaire agreements with Norwegian media raise questions about what should be classified as marketing costs versus sales commissions. We expect Norsk Tipping to maintain a clear distinction between the two and be able to document this,” said Monica Alisøy Kjelsnes, senior advisor at Lotteritilsynet.
Pressured by scrutiny, Norsk Tipping maintains that these commissions represent sales expenses rather than part of the advertising cap.
Debate Over Social Responsibility
Norsk Tipping argues that its broad media presence aids in steering players toward regulated gaming, thus limiting the risks of problem gambling. However, this justification meets heavy resistance. Spillavhengighet Norge emphasizes the risks that any gambling advertising poses, warning it can prompt relapses even among those recovering from lottery or jackpot-related gambling issues. Former problem gamblers have reported actively avoiding Norwegian news sites due to the prevalence of Norsk Tipping-related promotion.
Challenges for Gambling Policy in Digital Media
As physical retail distribution diminishes, digital media have become central to Norsk Tipping’s outreach. Critics argue that by incentivizing these outlets through turnover-based commissions, the operator may have adopted an affiliate-marketing model that potentially undermines the intention behind Norway’s gambling advertising restrictions. This raises the fundamental question of whether an effective advertising cap exists when media partners have a direct financial interest in customer gambling activity.
- Author
Daniel Williams
