Three questions about Finnish search advertising that nobody can answer yet

Finland’s market opens on 1 July 2027. The new Gambling Act handles marketing with a closed list: six paragraphs setting out what a licence holder may do, and a seventh saying everything else is prohibited.

Search advertising is on the list. What is not obvious is how much of search.

As I read the wording, marketing may be attached only to searches for the licensed operator itself, or to word searches directly related to its gambling products. That sentence is doing a lot of work, and I do not think anyone yet knows exactly how much.

I am writing this partly to think it through and partly in the hope that someone who knows better will tell me I have it wrong.

Where does “directly related” end?

Your own brand is clearly in. A category term like nettikasino is, I think, clearly out, because it describes the market rather than your products.

Between those two sits a layer that is genuinely unclear. If you offer poker, is nettipokeri a search directly related to your gambling products? If you offer slots, what about kolikkopelit? A reasonable person could argue either way, and the difference in available search volume between the two readings is not small. In Finnish search data, the game-type terms are roughly the same order of magnitude as the category term itself.

There is a complication that makes this harder rather than easier. The Act also prohibits advertising individual games. So a reading where you may bid on a game-type keyword but may not mention that game in the ad copy is at least possible. I am not sure that reading is coherent, but I am also not sure it is wrong.

What happens to campaign types that cross channels?

This question gets less attention than the keyword one, and I suspect it matters more.

The permitted list is a list of channels: broadcast, print and equivalent electronic publications, outdoor, your own site, your own social accounts, search. It is not a list of outcomes or budgets. It is a list of places.

Performance Max is not a place. It serves across Search, YouTube, Display, Gmail, Discover and Maps, and the advertiser cannot fully control or afterwards prove where a given impression ran. If the channel list really is closed, it is hard to see how you demonstrate compliance for a campaign type whose placement you cannot account for.

If that reading holds, then the most automated part of Google Ads is the part Finland effectively closes, and the manual, tightly controlled search campaign becomes the thing you build. That would be an unusual outcome in 2027 and worth knowing about before anyone writes a media plan.

Who actually decides, and when?

This one I think I do understand, and it surprises people.

Google is not the enforcer here. Google’s gambling policy requires certification, and certification checks that you hold a Finnish licence. It does not inspect your keyword list against Finnish marketing law. Once you are certified, the platform will run your ad on whatever you ask it to.

The Act binds the operator, not the platform. Nothing stops you at the point of purchase. The consequence, if there is one, arrives later and comes from the supervisory authority: a warning, an administrative fine, and in the worst case the licence itself.

So every operator entering Finland has to make a judgment call in a space where no authority has yet drawn the line, and where the platform will cheerfully let you cross it.

What I would do in the meantime

Plan on the narrow reading. If it turns out to be too cautious, you have left some volume on the table for a while and you can widen later. If you plan on the wide reading and it turns out to be narrow, you have built an acquisition channel you are not allowed to use, and you find out after launch.

That asymmetry seems clear to me even though almost nothing else here does.

If you have read the Act differently, or you have asked a regulator and received an answer, I would genuinely like to hear it.

Not legal advice. This is a practitioner reading a statute, not a lawyer interpreting one. Check anything here with a Finnish gambling lawyer before it drives a commitment.