Comparing gambling advertising codes across the UK, Italy, Spain and Ontario reveals four regulators answering the same question in four incompatible ways. One market bans promotion entirely. One polices creative content through a self-regulatory code. One saw several of its restrictions struck down in court. One allows advertising but keeps every bonus offer behind the login. One creative cannot satisfy all four, which is why GICNT-AM advertising requirements are applied market by market.
How the Four Advertising Regimes Compare
The four markets sit at different points on one axis: how much of a commercial message a supervisor will tolerate in public space. Advertising oversight does not always sit with the body that issues the licence, a split visible across the reference table of gambling regulators by country and one that decides where a complaint lands.
| Market | Governing instrument | Public advertising | Bonus and inducement advertising | Athletes and public figures | Supervisor |
|---|---|---|---|---|---|
| Great Britain | CAP and BCAP Codes, plus the LCCP | Permitted, with content restrictions | Permitted; wagering capped at 10 times bonus value | No categorical ban; strong appeal test applies | ASA and the Gambling Commission |
| Italy | Article 9, decreto-legge 87/2018 (Decreto Dignità) | Prohibited in any form, direct or indirect | No lawful public channel | No advertising role available | AGCOM |
| Spain | Royal Decree 958/2020, partly annulled in 2024 | Permitted; several restrictions annulled | Acquisition promotions restored on 2 April 2024 | Permitted since the ban on public figures fell | DGOJ |
| Ontario | Registrar’s Standards for Internet Gaming | Permitted, with placement restrictions | Public promotion prohibited (Standard 2.05) | Athletes prohibited since 28 February 2024 | AGCO |
Advertising Rules in Great Britain Run Through Two Rulebooks
Two systems operate in parallel. The CAP Code covers non-broadcast media and the BCAP Code covers broadcast, both enforced by the Advertising Standards Authority. Separately, the Gambling Commission imposes obligations through the Licence Conditions and Codes of Practice, so advertising rules for gambling operators in the UK carry two enforcement routes, one ending in an ASA ruling and one in a licence review.
The content test changed in 2022, when CAP and BCAP replaced the previous test of particular appeal with a stricter test of strong appeal, catching creative that might unduly attract the attention of under-18s even where the audience is adult. Guidance updated in October 2025 added a working threshold: at least 100,000 under-18 follower accounts across social platforms is indicative of strong appeal, although the ASA can rule either way on context.
Two rulings on 27 May 2026 show where the line now sits. A post featuring two current top-flight footballers was found to breach the Code; a post featuring a retired player working as a pundit, with a low proportion of UK under-18 followers, was not. The ASA also confirmed that unpaid posts on an operator-controlled channel fall within the Code when they are connected with the supply of betting services.
A sweep of almost 400 posts on Meta platforms covering August 2025 to March 2026 found roughly 85% either compliant or outside the scope of the rules, and around 5% clearly problematic and taken forward for enforcement. An enforcement notice put operators on notice of active monitoring from 11 June 2026, with content outside CAP remit referred onward to the Gambling Commission, whose LCCP and licensing objectives cover the same conduct from the licence side.
Italy Prohibits Gambling Advertising in Any Form
Article 9 of decreto-legge 87/2018, converted by law 96/2018 and known as the Decreto Dignità, is not a content code. It removes the category. The Italian gambling advertising ban runs as follows:
- any form of advertising, direct or indirect, on any medium, covering sporting, cultural and artistic events, television and radio, the press, and digital and telematic channels including social media
- liability attaching simultaneously to the party commissioning the message, the owner of the medium or destination site, and the organiser of the event or activity
- a penalty of 20% of the value of the sponsorship or advertising and, in any event, not less than EUR 50,000 for each breach
Enforcement has been uneven. AGCOM recorded EUR 12.39 million in advertising penalties in 2023 and EUR 1.81 million in 2024, then no new financial penalties in 2025, a gap the authority attributes to pending litigation. On 29 July 2025 the Lazio administrative court referred the fixed minimum to the Constitutional Court; the referral was published in the Gazzetta Ufficiale on 18 February 2026 and argued on 24 June 2026. The referral concerns proportionality of the sanction floor, not the ban itself, which no party has challenged.
The remaining question is what a licensed operator may still say. Delibera 200/26/CONS of 29 July 2026 supplements AGCOM guidance on communication campaigns against gambling disorders: no direct or indirect invitation to play, no reference to odds, bonuses, jackpots or prizes, a prevention message that clearly prevails, particular caution over testimonials and influencers, and no route from a responsible gambling message straight into the gambling platform. Because liability follows whoever owns the medium, the ban reaches partner channels directly, which is why operator liability for affiliate partners is handled as a compliance function rather than a commercial one.
What Spain Permits After the Supreme Court Struck Down Parts of Royal Decree 958/2020
Spanish gambling advertising regulation was the most restrictive in Europe for roughly three years, and then it was not. Judgment 527/2024 of the Third Chamber of the Tribunal Supremo, dated 2 April 2024, partly upheld a challenge brought by the online gambling association Jdigital and annulled several articles of Royal Decree 958/2020 on the ground that they lacked cover in the enabling statute.
Annulled were article 13, paragraphs 1 and 3, on promotional activity directed at new customers; article 15, on the appearance of persons of public notoriety; article 23, paragraph 1, imposing a general prohibition on commercial communications through information society services; article 25, paragraph 3, on video-sharing platforms; and article 26, paragraphs 2 and 3, limiting advertising through social networks.
The decree survives elsewhere. Identification of commercial communications, responsible gambling requirements, protection of minors and self-excluded players, and the regulator’s power under article 13.10 to set further conditions on promotions aimed at existing customers all remain in force. The gap is being closed through primary legislation rather than a second regulation: on 18 May 2026 the consumer affairs ministry opened a public consultation on amending the 2011 Gambling Act, which closed on 22 June 2026 with more than fifty submissions. Stated targets include celebrities and influencers in gambling advertising, customer acquisition promotions, and organic search advertising, so that only authorised operators surface on directly related queries.
One measure sits outside advertising altogether and matters more for certification. The DGOJ is developing an early detection model for problem gambling built on real microdata, mandatory for every licensed operator, which the regulator estimates could raise current detection rates by around ten percentage points. A mandatory model moves the compliance question from copy approval to conduct, since detecting markers of harm becomes a supervised process rather than an internal choice.
Ontario Keeps Bonus Offers Behind the Login
Ontario permits gambling advertising and then removes its most persuasive element from public view. Four provisions of the Registrar’s Standards for Internet Gaming do the work:
- Standard 2.05: advertising and marketing that communicates inducements, bonuses and credits is prohibited except on the operator’s own gaming site and through direct marketing after active player consent. The prohibition covers targeted and algorithm-based advertising, not only broadcast and outdoor.
- Standard 2.06: permitted bonus communications must disclose all material conditions and limitations at first presentation on the gaming site, with any remaining conditions no more than one click away, and may not describe an offer as free or risk-free where the player must risk or lose their own money.
- Standard 2.07: consent to direct marketing of inducements is opt-in and must be withdrawable at any time.
- Standard 2.03, in force since 28 February 2024: athletes may not appear in gaming advertising at all, except in material promoting responsible gambling exclusively; celebrities, role models, social media influencers, entertainers, cartoon figures and symbols likely to appeal to minors are prohibited; billboards directly adjacent to schools or other youth-oriented locations are prohibited; and material must not knowingly be sent to high-risk players.
Ontario iGaming advertising standards therefore restrict the audience of the offer rather than the offer itself. Inducements remain lawful and widely used, while their public promotion does not exist as a channel. Because the same document governs registration and conduct, AGCO Registrar’s Standards are read as a single instrument rather than as a marketing annex to a licence.
Where Athletes and Public Figures May Still Appear
| Market | Athletes | Other public figures | Basis |
|---|---|---|---|
| Great Britain | No categorical ban, but barred where the individual is of strong appeal to under-18s | Nobody who is or appears to be under 25 may play a significant role | CAP and BCAP Codes |
| Italy | No advertising role exists to fill | Caution urged even in prevention campaigns, where the message must prevail over the face delivering it | Article 9 and delibera 200/26/CONS |
| Spain | Permitted since article 15 was annulled on 2 April 2024 | Permitted for now; restriction is an explicit objective of the pending reform | Royal Decree 958/2020 as annulled |
| Ontario | Prohibited outright, except in responsible gambling messaging | Prohibited where likely to appeal to minors, influencers included | Standard 2.03 |
Celebrity endorsement in gambling ads is the clearest divergence of the four. The same signing is a registration breach in Ontario, a content risk in Great Britain depending on who the audience is, unremarkable in Spain today, and legally impossible in Italy. Global sponsorship contracts drafted before 2024 rarely account for that.
How Bonus Terms Must Be Disclosed Before a Player Accepts
Requirements for disclosing bonus terms diverge as sharply as the rules on who may deliver the message:
- Great Britain: under social responsibility code 5.1.1, wagering requirements may not exceed 10 times the bonus value, in force from 19 December 2025. Incentives mixing more than one product category, meaning betting, casino, bingo and lottery, are prohibited from 19 January 2026, with the qualifying activity and the reward required to fall in the same category unless the customer’s choice of product is entirely unrestricted. Consent to direct marketing has been required on a channel and product basis since 1 May 2025.
- Ontario: conditions at first presentation on the gaming site, the remainder one click away, and no use of the words free or risk-free where the player has money at stake.
- Spain: promotions to new customers are lawful again after the 2024 annulment, but the regulator retains the power to impose further conditions on promotions aimed at existing customers, and acquisition promotions are named in the reform consultation.
- Italy: no disclosure standard applies, because the offer cannot be communicated in public at all.
The British caps did not originate in advertising policy. They are the marketing edge of Gambling Act review implementation, which is worth tracking for operators who model bonus economics on a jurisdiction-by-jurisdiction basis.
What GICNT-AM Requires Beyond the Local Code
GICNT-AM does not restate any national code. It sets a floor that holds wherever the campaign lands:
- a creative baseline set to the strictest regime the campaign can reach, not the most permissive one in the media plan
- responsible gambling messaging present in all marketing material, not only in campaigns dedicated to it
- bonus conditions visible before acceptance rather than surfaced after the deposit
- no targeting of minors, self-excluded players, or segments already identified internally as high risk
- documented approval of affiliate creative, with the operator answerable for partner output
GICNT-AM is the only domain of the framework reviewed on complaint rather than on a schedule, a deliberate exception to the audit cycles and review frequency applied to the other five. The practical consequence is that an operator has no advance notice: the trigger is a complaint, and the evidence assessed is whatever was live at the time it was filed.
Advertising Code Questions Operators Ask Most Often
Do advertising codes apply to an operator’s own organic social posts?
In Great Britain, yes. The ASA has confirmed that unpaid posts in space controlled by the advertiser fall within the CAP Code where they connect with the supply of betting services. Ontario treats targeted and algorithm-based advertising as public advertising under Standard 2.05, and the Italian ban names social media explicitly.
Can one creative run across the UK, Spain and Ontario?
Rarely, and never if it shows a bonus. A bonus visible in public breaches Ontario Standard 2.05 while remaining lawful in Great Britain and Spain. A current footballer with a large under-18 following is a British problem and an Ontario prohibition. In practice the media plan has to be split by market before the creative is signed off.
Would the Constitutional Court case lift Italy’s advertising ban?
No. The referral from the Lazio administrative court concerns whether a fixed minimum penalty of EUR 50,000 per breach is proportionate, not whether the prohibition itself is lawful. Even a successful challenge would leave the ban and the 20% criterion in place, with the fixed floor removed.
Are welcome bonuses advertised lawfully in Spain again?
Promotions directed at new customers are no longer prohibited by Royal Decree 958/2020, since the paragraphs imposing that restriction were annulled on 2 April 2024. General obligations on transparency, identification and responsible gambling still apply, and acquisition promotions are listed among the objectives of the pending legislative reform.
Who is liable when an affiliate breaches an advertising code?
The operator, in every one of the four markets, though by different routes. Ontario holds the registrant answerable for the conduct of partners promoting it. Great Britain treats a code breach by a licensee’s marketing chain as a licence matter as well as an ASA matter. Italy goes furthest by attaching liability to the owner of the medium alongside the party commissioning the message.