Insights

The Biggest CLO Industry Challenges Facing Advertisers

The card-linked offer ecosystem has expanded rapidly over the last several years. However, as more publishers, wallets, financial institutions, and loyalty platforms enter the space, many advertisers are facing new CLO industry challenges that go beyond simply launching offers.

What was once a relatively centralized ecosystem has evolved into a fragmented network of providers, integrations, and reward environments. As a result, advertisers are increasingly being asked to manage operational complexity, overlapping attribution, and inconsistent reporting across multiple CLO partners.

At the same time, pressure to prove incrementality and marketing efficiency continues to grow.

For many brands, the question is no longer whether to invest in card-linked offers—it’s how to scale them intelligently.

The CLO Ecosystem Has Become Increasingly Fragmented

One of the largest CLO industry challenges today is fragmentation.

As the ecosystem expands, advertisers often work across multiple:

• Financial institutions
• Publisher networks
• Loyalty platforms
• Wallet providers
• Airline and travel programs

On the surface, this creates broader reach. However, behind the scenes, it can introduce operational inefficiencies that become increasingly difficult to manage at scale.

In many cases:

• Offers run across disconnected systems
• Reporting structures vary by partner
• Ownership becomes unclear
• Campaign workflows duplicate across platforms

As a result, advertisers may struggle to maintain visibility into where offers are distributed, how performance is measured, and whether spend is being allocated efficiently.

Attribution and Deduplication Remain Major CLO Industry Challenges

As more publishers participate in the CLO ecosystem, advertisers are also encountering new attribution concerns.

Without centralized deduplication processes, the same transaction may be exposed to multiple publishers across different environments. This creates challenges around:

• Attribution accuracy
• Budget allocation
• Incrementality measurement
• Reporting reconciliation

In some cases, advertisers risk paying multiple times for the same transaction while still lacking a clear understanding of which placement actually influenced the purchase.

Consequently, many brands are reevaluating how CLO campaigns should be managed and measured across the broader ecosystem.

Why Intent Matters More Than Passive Reach

Another emerging shift within the industry is the growing focus on engagement quality—not just audience size.

Historically, many rewards environments operated through passive or “always-on” experiences. However, advertisers are increasingly prioritizing signals that indicate active purchase intent.

This is where click-to-activate engagement models have gained attention.

When consumers actively engage with an offer before purchasing, advertisers gain:

• Clearer intent signals
• Stronger attribution visibility
• Better alignment between engagement and conversion behavior

As measurement standards evolve, high-intent engagement is becoming an increasingly important differentiator across the CLO landscape.

Scale Without Governance Creates New Problems

The CLO ecosystem continues expanding rapidly across:

• Banks and financial institutions
• Digital wallets
• BNPL platforms
• Airline and travel ecosystems
• Retail and dining environments

While this growth creates opportunity, it also introduces additional CLO industry challenges for advertisers trying to maintain control across multiple activation points.

More access does not always create more efficiency.

Without centralized visibility and governance, advertisers may encounter:

• Budget leakage
• Overlapping exposure
• Inconsistent customer experiences
• Fragmented campaign reporting

As a result, scale alone is no longer enough. Increasingly, advertisers are prioritizing infrastructure that supports operational clarity alongside distribution growth.

What Advertisers Are Starting to Prioritize

As the industry matures, advertiser expectations are evolving as well.

Today, brands increasingly look for:

• Unified reporting
• Deduplicated transaction measurement
• Flexible campaign structures
• Holistic performance visibility
• Easier integrations across existing marketing stacks

Additionally, advertisers want greater transparency into how offers are distributed across publisher ecosystems and how incremental performance is measured.

These priorities reflect a broader shift happening across the industry: moving from isolated CLO placements toward more coordinated network strategies.

The Next Phase of the CLO Industry

The next phase of growth in card-linked offers will likely be defined by efficiency, interoperability, and measurement transparency.

Advertisers are no longer evaluating CLO programs solely based on publisher access. Instead, they are increasingly evaluating:

• Operational simplicity
• Attribution accuracy
• Deduplication capabilities
• Incremental performance
• Long-term scalability

These evolving expectations are reshaping how the industry approaches campaign management and ecosystem partnerships.

Ultimately, the brands that succeed in navigating future CLO industry challenges will be those that balance scale with control—and performance with measurement clarity.

Continue the Conversation

As the CLO ecosystem continues evolving, advertisers have an opportunity to rethink how campaigns are managed, measured, and scaled across increasingly complex publisher environments.

Connect with the Rakuten Card Linked Offers Network team to learn how leading advertisers are approaching the next phase of CLO growth and measurement.