Do gambling affiliates need an ONJN licence?
For an affiliate placing Romanian gambling traffic, the short answer is usually yes. Under GEO 77/2009 as amended, a marketing affiliate is treated as a BClass 2 supplier guideB supplier to the regulated market and is required to hold a Class Class 2 supplier guide authorisation from the ONJN (Oficiul Național pentru Jocuri de Noroc), the Romanian National Gambling Office. The scope of Class Class 2 supplier guide and the categories it captures are set out in our Class 2 supplier guide; this piece looks at the affiliate case specifically.
The logic is structural. Romanian Class operators are permitted to source services only from Class -authorised suppliers, and an affiliate that sends them player traffic is supplying such a service. The consequence runs both ways: an unlicensed affiliate is not merely exposed itself, it also puts its Class customers in breach of their own licence conditions. That reciprocity is why compliant operators will not contract with affiliates who cannot show a Class entry.
If you earn from Romanian player traffic you route to a licensed operator, the default position is that you need Class .
What counts as an affiliate under Romanian law
The regulatory definition is functional, not contractual. An affiliate is, in substance, any natural or legal person that earns revenue under a contract with a BC online operator as a result of players it redirects onto that operator's platform. The label the parties use — publisher, media partner, introducer — does not change the analysis. What matters is the combination of two facts: Romanian players and remuneration tied to the traffic.
This captures the obvious cases — comparison sites, streamers, tipster channels, display networks running gambling creative — and some less obvious ones. A generalist media business that runs a gambling section on revenue-share is an affiliate for these purposes. So is an individual running a Romanian-language betting-tips channel monetised through operator links. The regime does not exempt small operators or individuals; the RON , to RON , contravention fine for unlicensed BB activity applies to a sole trader as readily as to a network.
When Class is required — and the narrow safe harbour
The core question the task turns on is whether every affiliate needs Class , and the honest answer is that the exceptions are narrow and fact-specific rather than a reliable planning route. Class is required where the affiliate targets Romanian players and is remunerated by a licensed Romanian operator. Both limbs must be present.
- Targeting is assessed on substance — Romanian-language content, a .ro domain or Romanian-facing marketing, RON pricing, or promotion of operators licensed for Romania all point to it. A .ro domain is a strong indicator but not the sole test; a Romanian-language site on an international domain can still be targeting.
- Remuneration means a commercial arrangement with a BC operator keyed to player activity — revenue-share, CPA, or a hybrid. A publisher paid a flat editorial fee unconnected to player outcomes is in a different, weaker position, though rarely a clean one.
Where an affiliate genuinely does not target Romania — no Romanian-language marketing, no Romanian operators promoted, no RON — it may fall outside the perimeter. But an affiliate cannot both monetise Romanian traffic through licensed operators and claim to be outside the regime. Operators, bound by their own licence conditions, will in any case decline uncredentialed affiliates, so the commercial reality tracks the legal one. Treat the safe harbour as a description of who is not an affiliate, not as a structuring option.
Advertising restrictions that bind marketing partners
Holding Class does not license unrestricted promotion. Romanian gambling-advertising rules, tightened materially in and , bind affiliates directly:
- Bonus and promotional offers may be advertised only on limited channels — the operator's own website, a Class -licensed affiliate's website, or messages to a licensed operator's active players. An unlicensed affiliate cannot lawfully carry bonus advertising at all.
- Outdoor advertising exceeding square metres per panel is prohibited, and outdoor placement is barred in or near educational, socio-cultural, and religious premises.
- Unsolicited electronic messaging promoting gambling to an open-ended list of recipients is prohibited, and advertising may not be sent to self-excluded players.
- Public figures — from politics, culture, science, or sport, and online personalities whose notoriety may encourage participation — may not feature in gambling advertising, following the audiovisual rule change in force from October .
- Audiovisual gambling commercials face a daytime broadcast prohibition between : and :, with a carve-out for betting commercials during live sports.
These are the affiliate's own obligations, not merely the operator's. A Class affiliate running non-compliant creative exposes itself, and jeopardises the licence conditions of every operator it works with.
The % advertising-contract fee
Romania levies a fee of % on the value of gambling advertising contracts, payable in connection with the promotion of gambling activity. Operators must report advertising contracts to ONJN within five working days of conclusion. The one material carve-out is for contracts with sports entities or federations obliging them to advertise within stadiums or sports halls, which fall outside the % charge.
For an affiliate, the fee is a commercial fact to price into deals even where the operator is the statutory payer: it shapes what operators will pay for advertising placements and how contracts are structured and reported. It sits on top of, not instead of, the affiliate's own Romanian corporate tax — a Class affiliate is a normal Romanian taxpayer, and because gambling is excluded from the microenterprise regime under Article of the Codul Fiscal, an affiliate SRL earning gambling revenue pays standard % corporate income tax on profit rather than the OUG 82/2023% micro rate — on top of the operator-level % gaming-revenue tax under OUG 82/2023 that shapes the wider market.
Revenue-share versus CPA treatment
The two dominant affiliate models — revenue-share (a percentage of the net revenue generated by referred players) and CPA (a fixed fee per acquired, qualifying player) — are treated the same way for authorisation purposes. Both are supply of an affiliate service to a Class operator, and both require Class where the targeting and remuneration limbs are met. The choice between them does not change whether a licence is needed.
Where the models diverge is in accounting and record-keeping. Revenue-share ties the affiliate's income to ongoing player activity, which means the affiliate must retain data linking commissions to referred players and their outcomes over time — records that must be audit-ready if ONJN extends an inspection of a Class operator to its suppliers. CPA is cleaner to evidence per acquisition but concentrates commercial risk in the qualification criteria. Hybrid deals combine both exposures. None of this alters the licensing answer; it alters the documentation burden the affiliate carries once licensed.
The risk position of an unlicensed affiliate
An affiliate placing Romanian traffic without Class is not in a tolerated grey zone. Carrying out BB activity without the required Class authorisation is an administrative offence sanctioned by a fine of RON ,blacklist to RON ,blacklist and confiscation of amounts derived from the activity. Beyond the fine, ONJN identifies websites used to market or promote unlicensed gambling and communicates them to internet service providers for access blocking, and adds domains and brands to its blacklist — which ran to roughly , domain names at the most recent published tally.
The exposure compounds where an affiliate promotes an unlicensed operator. Class operator verification guide holders are expressly prohibited from providing services to unlicensed entities targeting Romania, and recent amendments to GEO 77/2009 — the framework approved by Law 124/2015 — criminalised a broader range of acts facilitating unauthorised gambling — including a Class operator verification guide holder supplying services to sites offering remote gambling accessible from Romanian IP addresses without a Class Law 124/2015 licence. An affiliate's first compliance task, before placing any traffic, is therefore to verify that the operator it promotes is itself licensed; our operator verification guide sets out how to read the register.
Promoting an unlicensed operator is not a lesser breach than being unlicensed yourself — it is its own offence.
Getting Class as an affiliate: capital, timeline, cost
An affiliate obtains the same Class authorisation as any other BB supplier. The headline requirements:
- Corporate vehicle — a Romanian SRL or SA, registered at the Trade Register, with a Romanian address and commercial presence; once granted, the affiliate appears on the Class 2 supplier register.
- Capital — the Class floor of RON .m, fully paid in and held in a Romanian operating account. This is the single largest barrier for smaller affiliates, and it is real.
- Licence structure — a ten-year licence to organise paired with an annual operating authorisation, so the affiliate must budget for renewal, not a one-off grant.
- Timeline — a clean Class file typically clears in to months, materially faster than a Class grant.
The capital floor means Class rarely makes sense for a marginal affiliate operation; it suits established networks and media businesses with material Romanian volume. Smaller affiliates more often route Romanian traffic through a licensed intermediary that already holds Class , rather than capitalising their own entity. The full mechanics — dossier, fit-and-proper review, fees, and integration with Class ONJN licensing pillar operators — are in our Class 2 supplier guide and the ONJN licensing pillar.
A compliance checklist for marketing partners
For an affiliate assessing its Romanian position:
- Confirm you are within the perimeter — Romanian targeting plus operator-linked remuneration. If both are present, assume Class is required.
- Verify every operator you promote is licensed, on the ONJN Class 1 register, and not blacklisted, before placing traffic.
- Hold Class or route through a licensed intermediary — do not place Romanian traffic on the strength of a foreign licence alone.
- Bring creative into line with the advertising restrictions — bonus-channel limits, the -square-metre outdoor cap, the public-figures ban, and the self-exclusion and unsolicited-messaging rules.
- Keep audit-ready records linking commissions to referred players, on the assumption an ONJN inspection of a Class partner can reach you.
Getting this wrong is not a paperwork risk; it is a fine, confiscation, and domain-blocking risk that also damages the operators you depend on. Treat the licence and the advertising rules as a single compliance surface.
Frequently asked questions
Do gambling affiliates really need a Class licence in Romania?
In most cases yes. Under GEO / a marketing affiliate is a BB supplier and needs ONJN Class authorisation where it targets Romanian players and is remunerated by a licensed operator. Class operators may only contract with Class -authorised suppliers, so compliant operators will not work with an affiliate that cannot show a Class entry.
Is there any way to affiliate in Romania without Class ?
Only by genuinely not being an affiliate for Romanian purposes — no Romanian-language marketing, no Romanian operators promoted, no player-linked remuneration from Romanian traffic. In practice, smaller affiliates route Romanian traffic through a licensed intermediary that holds Class rather than capitalising their own entity. There is no reliable way to monetise Romanian traffic through licensed operators while claiming to be outside the regime.
Does the licensing requirement differ for revenue-share versus CPA?
No. Both revenue-share and CPA are supply of an affiliate service to a Class operator and both require Class where the targeting and remuneration limbs are met. The models differ in record-keeping — revenue-share requires retaining data linking commissions to referred players over time — but not in whether a licence is needed.
What happens if I place Romanian traffic without a licence?
Unlicensed BB activity is an administrative offence carrying a fine of RON , to RON , plus confiscation of amounts derived. ONJN also blocks marketing domains at ISP level and blacklists them. Promoting an unlicensed operator is a separate, more serious breach that recent amendments to GEO / criminalised.
What are the main advertising restrictions on affiliates?
Bonus advertising is limited to the operator's own site, a Class -licensed affiliate's site, or messages to active players; outdoor panels over square metres are prohibited; public figures may not feature in gambling adverts from October ; unsolicited messaging and advertising to self-excluded players is prohibited; and audiovisual commercials are barred between : and : with a live-sports betting carve-out.
What is the % advertising fee?
Romania levies a % fee on the value of gambling advertising contracts, and operators must report advertising contracts to ONJN within five working days of conclusion. Contracts with sports entities or federations for advertising inside stadiums or sports halls are exempt. Affiliates should price the fee into placement deals even though the operator is typically the statutory payer.
Talk to us
If you place Romanian gambling traffic, the licensing and advertising position is worth resolving before you sign your next operator deal, not after. We advise affiliates and marketing partners on whether Class our pricing is required, structure the Romanian entity and capital, and manage the ONJN application. See our iGaming licensing service, then book a 30-minute call or review our pricing.
Related guides
- ONJN Class 2 (B2B) supplier authorisation — the authorisation affiliates apply for
- ONJN-approved operators: how to verify a licence — check an operator is licensed before promoting it
- Romanian iGaming licensing under ONJN: the complete 2026 guide — the pillar overview of the regime
- Romania's iGaming tax stack: the 27% revenue tax — the fiscal backdrop for gambling businesses
- ONJN Class 1 (B2C) authorisation in detail — the operators affiliates send traffic to
- Romanian SRL formation: the complete 2026 guide — forming the entity that holds Class