GICNT-AM: Advertising and Marketing Standards

Standards for gambling advertising diverge between markets to the point where a single creative asset is lawful in Malta and sanctionable in Milan. GICNT-AM sets the floor a certified operator holds in every market it addresses, whatever the local code permits. The domain is Mandatory. Unlike the other five, it is reviewed on complaint rather than on a fixed calendar, which puts the burden of evidence on the operator.

What GICNT-AM Covers and Which Channels Sit Inside Its Scope

Compliance with gambling advertising rules breaks down at the edges of what a marketing team counts as an advert. Of the six domains of the GICNT framework, this is the one where somebody outside the operator’s own building can generate the breach. GICNT-AM therefore defines a commercial communication as any material the operator controls, pays for, or benefits from under a commercial agreement. Neither ownership of the channel nor the presence of a media spend narrows that definition.

The domain reaches:

• Paid placements across display, search, television, radio and outdoor
• Owned social accounts, including organic posts, replies and pinned content
• Influencer, streamer and ambassador content produced under a commercial agreement
• Affiliate reviews, comparison tables and bonus landing pages
• CRM output: email, SMS, push notifications and in-product offers
• Sponsorship assets such as shirt branding, perimeter boards and event naming rights
• Promotional copy wherever it sits, including the terms page behind an offer

Regulators read their own remit the same way. In a ruling published on 27 May 2026, the Advertising Standards Authority treated a post in non-paid-for online space under an advertiser’s control as a marketing communication, because it connected directly to the supply of betting services, and rejected the argument that the content was editorial. An operator that scopes its advertising controls to paid media has already lost most of the surface area.

Advertising Must Not Be Directed at Minors or Vulnerable Groups

Every major regime bans advertising targeted at minors. What differs is the test each regulator applies to decide whether an asset is targeted, and gambling advertising codes diverge more on that question than on anything else in the domain.

Jurisdiction	Instrument	Test applied to the creative
Great Britain	CAP and BCAP Codes	Content must not be of strong appeal to under-18s, a stricter benchmark than the particular appeal test it replaced in 2022
Ontario	Registrar’s Standards for Internet Gaming, Standard 2.03	Athletes, active or retired, prohibited outside responsible gambling advocacy; celebrities, influencers, entertainers and cartoon figures restricted where they would likely appeal to minors
Germany	GlüStV 2021, § 5(2) and § 5(3)	Advertising must not address minors or comparably vulnerable groups; active athletes and officials cannot appear in sports betting advertising
Netherlands	Remote Gambling Act as tightened since 2023	Role models prohibited; untargeted advertising banned since 1 July 2023 and sports sponsorship since 1 July 2025
Sweden	Spellagen (2018:1138), chapter 15	Marketing must meet the moderation standard and must not reach under-18s or anyone registered with Spelpaus
Italy	Decreto Dignità (Law 96/2018), article 9	Near-total prohibition of gambling advertising and sponsorship, direct and indirect

GICNT-AM requires the operator to apply the strictest applicable test to any asset used in more than one market, and to hold the audience data supporting that decision. Great Britain shows why the data matters. Guidance updated in 2025 treats a total of 100,000 under-18 follower accounts across platforms as indicative of strong appeal, while stating that the count alone settles nothing and that context governs the assessment. CAP issued an enforcement notice on the point and began active monitoring on 11 June 2026.

Two regimes reach past the creative into scheduling and casting. The Glücksspielstaatsvertrag 2021, Germany’s interstate treaty on gambling, bars broadcast and internet advertising for virtual slot games, online poker and online casino games daily between 06:00 and 21:00, and bars betting advertising on the transmitting channel immediately before or during a live sports event for bets on that event. Ontario went after the people in the frame instead: the amended Standard 2.03 took effect on 28 February 2024 and removed athletes from igaming advertising altogether, with one exception for responsible gambling advocacy.

Where Responsible Gambling Messaging Has to Appear

GICNT-AM requires messaging on responsible gambling in every commercial communication, sized and timed so that somebody actually reads it in the format the asset is served in. A five-second pre-roll and a static billboard do not get the same treatment. A disclosure nobody can read counts as no disclosure.

Italy has gone furthest in defining what a compliant safer gambling communication looks like. Licensed operators under the reformed online regime must spend 0.2% of net revenue, capped at EUR 1 million a year, on responsible gambling communications. AGCOM, the Italian communications authority, approved final guidelines on 29 July 2026 governing the optional self-branded version of those campaigns. Celebrities already tied to an operator’s commercial brand and the operator’s own promotional slogans are both prohibited. QR codes and links leading to the betting offer, bonuses or odds are out, while links to self-exclusion tools, deposit limits and helplines are permitted, provided the landing page carries no promotional content and does no profiling. AGCOM’s stated principle is that the brand must not be the most emphasised component and the protective message must outweigh it.

Spain is moving on wording rather than format. The DGOJ confirmed in early 2026 that it will phase out generic slogans such as juega con responsabilidad in favour of statements about the mathematical odds of losing. GICNT-AM takes the same position: a slogan on its own is insufficient, and the message has to name or reach a working control, which is why this domain is assessed alongside the responsible gambling tools an operator already owes under GICNT-PP.

Bonus Terms Must Be Disclosed Before the Customer Opts In

Disclosure of bonus terms produces more advertising complaints than any other single issue. GICNT-AM requires the following to sit with the headline offer rather than behind a link:

• The wagering requirement, expressed as a multiple of the bonus
• The qualifying deposit and any minimum odds
• Which games or products count towards the requirement, and at what rate
• The expiry period
• Any cap on withdrawable winnings derived from bonus funds

The word free carries a specific meaning here. Where an offer requires a stake, a deposit or a play-through, the operator cannot call it free, and cannot call a bet risk-free where the stake is not returned in cash. Sweden’s moderation standard makes the same point, and the Swedish Consumer Agency reviews bonus terms against it.

Great Britain now regulates the structure of the offer as well as the copy. From 19 December 2025, an amended Social Responsibility Code 5.1.1 caps wagering requirements at 10 times bonus funds and prohibits mixed product promotional offers, so a bonus can no longer require a customer to play across betting and slots to qualify. Gambling Commission guidance published that same month extended the reasoning to free-to-play rewards. Both changes came out of the UK Gambling Act review and its 2023 white paper.

Suppressing Marketing to Self-Excluded and Opted-Out Customers

A certified operator has to show that suppression works end to end, not that a suppression list exists somewhere. Great Britain sets a deadline. A licensee must remove or flag a self-excluded person in the marketing databases used by the business or group within two days of receiving the completed self-exclusion notification, and must take all reasonable steps to stop any third party sending marketing on its behalf from breaching the same rule. Sweden bars marketing directed at anyone registered with Spelpaus, and the Netherlands blocks the untargeted channels where such a person would encounter it anyway.

Where exclusion runs through national self-exclusion registers rather than an operator scheme, the suppression duty still lands on the operator. GICNT-AM extends it to every copy of the customer file held outside the operator’s own systems: agency-side custom audiences, retargeting pools and lookalike models built from uploaded data. Those copies are where suppression usually fails, because nobody refreshes them.

How Far Operator Liability Extends to Affiliates and Media Partners

Great Britain answered this in its licence conditions. Social responsibility code provision 1.1.2 makes a licensee responsible for the third parties it contracts with, and requires the contract to:

• Require the third party to conduct itself, so far as it acts on the licensee’s behalf, as if bound by the same licence conditions and codes of practice
• Oblige the third party to supply whatever information the licensee needs to meet its reporting obligations to the Commission
• Allow prompt termination where the third party is in breach or has acted inconsistently with the licensing objectives, including where an affiliate has breached a relevant advertising code

Failure to keep adequate control of third parties can lead to suspension or loss of the operating licence. Italy adds direct exposure for the partner itself: AGCOM can fine an affiliate between EUR 50,000 and EUR 500,000, order immediate removal of the content and, in serious cases, have the site blocked.

GICNT-AM turns this into an evidence requirement. Compliance across affiliate marketing channels is assessed on what the operator can produce: the contract clauses, the creative approval log, the monitoring records, the termination file. The affiliate compliance obligations that follow apply to media partners, ambassadors and agencies on identical terms.

How a Complaint Triggers a GICNT-AM Review

The other five domains run on a calendar. This one runs on complaints, which means an operator can go a long stretch without contact and then have to produce a full record at short notice. The review works in four stages:

1. Intake. A complaint identifies the certified operator, the specific asset and the market it was served into.
2. Production. The operator supplies the asset as served, together with placement, targeting and flighting data, plus the approval record behind the creative.
3. Assessment. The asset is measured against GICNT-AM and against the advertising code of the jurisdiction it actually reached.
4. Remediation. Where the asset falls short, the operator withdraws or amends it inside a set period and shows what changed in the approval process that let it through.

Two practical consequences follow. An operator needs an archive of creative as served rather than as approved, because the two versions separate once a media buyer resizes an asset or an affiliate rewrites the bonus copy around it. And a reactive schedule is not a lighter one: complaint volume across a large partner programme can produce more contact than the annual cycle of any other domain. Frequency differs by design across the GICNT audit cycles, and the reactive model here reflects how advertising harm surfaces, through exposure rather than through scheduled sampling.