Gambling Influencer Marketing Regulation in the EU: Social Media, Streaming, and Compliance Requirements

The Rise of Gambling Influencer Marketing

Gambling influencer marketing has emerged as one of the most significant developments in gambling advertising over the past decade. As traditional advertising channels face increasing restrictions across Europe, operators have turned to social media personalities, streaming content creators, and online influencers to reach potential customers, particularly younger demographics.

This shift presents unique regulatory challenges. Unlike traditional broadcast advertising with established oversight mechanisms, influencer content often blurs the line between genuine entertainment and commercial promotion. The informal, personal nature of influencer content can make gambling appear normalized or glamorized in ways that concern regulators focused on problem gambling prevention and youth protection.

Key Platforms for Gambling Influencer Activity

Gambling promotion through influencers occurs across multiple platforms, each with distinct characteristics:

• Twitch: Live streaming platform where "casino streamers" broadcast gambling sessions, often with sponsored bankrolls from operators
• YouTube: Pre-recorded content including "big win" compilations, casino reviews, and betting tips
• Instagram: Lifestyle content featuring gambling brands, sponsored posts, and Stories
• TikTok: Short-form video content that can rapidly reach young audiences
• Twitter/X: Betting tips, promotional codes, and real-time event commentary
• Telegram/Discord: Community channels offering "VIP tips" and direct operator promotion

According to research published in the Journal of Gambling Studies, exposure to gambling content on social media significantly correlates with gambling participation among young people, driving regulatory concern across Europe.

EU-Level Legal Framework

While gambling advertising remains primarily a national competence, several EU-level instruments affect influencer marketing across member states.

Unfair Commercial Practices Directive (UCPD)

The Unfair Commercial Practices Directive (2005/29/EC) establishes core requirements affecting all commercial content, including influencer marketing:

The UCPD applies regardless of whether national gambling advertising laws specifically address influencer marketing, providing a baseline obligation for transparency.

Audiovisual Media Services Directive (AVMSD)

The revised Audiovisual Media Services Directive extends certain broadcast advertising rules to video-sharing platforms and potentially to user-generated content. Key provisions include:

• Video-sharing platforms must implement measures to protect minors from harmful content
• Product placement and sponsorship in audiovisual content must be clearly identified
• Member states may apply stricter national rules to gambling advertising

Digital Services Act (DSA)

The Digital Services Act, fully applicable from February 2024, introduces additional platform obligations relevant to gambling influencer content:

• Large platforms must provide advertising transparency, including disclosure of who paid for ads
• Prohibition of targeting minors with advertising based on profiling
• Requirement for platforms to act against illegal content when notified

Country-by-Country Regulation

Despite the EU-level framework, gambling influencer marketing rules vary dramatically across member states, reflecting different approaches to gambling advertising regulation more broadly.

Belgium: Complete Advertising Ban

Influencer Marketing Prohibited

Belgium implemented one of Europe's strictest gambling advertising frameworks in 2023, effectively banning all gambling advertising including influencer marketing. Key provisions:

• No gambling advertising permitted on social media platforms
• Influencers cannot promote gambling operators or products
• Affiliate marketing prohibited
• Operators face significant fines for violations
• Belgian Gaming Commission actively monitors digital channels

The Belgian approach represents the most restrictive end of the regulatory spectrum, extending prohibitions that existed for broadcast media to all digital channels.

Italy: Dignity Decree Restrictions

Broad Advertising Ban

Italy's 2018 "Dignity Decree" (Decreto Dignità) prohibits gambling advertising across most channels, including social media. The ban covers:

• All direct and indirect gambling advertising
• Influencer promotion of gambling products
• Sponsorship by gambling operators
• Affiliate marketing content targeting Italian audiences

Enforcement has been active, with ADM (Agenzia delle Dogane e dei Monopoli) pursuing cases against operators and publishers. However, enforcement against individual influencers remains challenging when content originates outside Italy.

Netherlands: KSA Enforcement Actions

Heavily Restricted

The Netherlands Gambling Authority (Kansspelautoriteit or KSA) has taken aggressive action against influencer marketing. Notable measures include:

• Prohibition of advertising targeting under-24s (effectively limiting most social media promotion)
• Ban on using celebrities, athletes, and influencers in gambling advertising
• Requirement that advertising reach at least 95% adults aged 24+
• Active enforcement against streamers and social media influencers
• Fines of up to €600,000 for operators violating advertising rules

The KSA has specifically warned licensed operators that they bear responsibility for influencer marketing conducted on their behalf, even when influencers operate independently. This creates significant compliance risk for affiliate marketing arrangements.

Spain: DGOJ Registration Requirements

Heavily Regulated

Spain's 2021 Royal Decree on Commercial Communications in Gambling (Real Decreto 958/2020) established detailed influencer marketing requirements:

• Influencers promoting gambling must register with DGOJ (Dirección General de Ordenación del Juego)
• Promotion restricted to 1am-5am broadcast hours (same as traditional advertising)
• Prohibition of using celebrities, athletes, or public figures in advertising
• All promotional content requires prior regulatory notification
• Mandatory responsible gambling messaging

DGOJ has actively enforced these provisions, issuing guidance specifically addressing social media and streaming content. The registration requirement creates a paper trail enabling enforcement.

Germany: Interstate Treaty Restrictions

Regulated with Strict Rules

Germany's Interstate Gambling Treaty (Glücksspielstaatsvertrag) applies comprehensive advertising restrictions to influencer marketing:

• All gambling advertising restricted to 9pm-6am except for sports betting during live events
• Mandatory responsible gambling warnings and OASIS self-exclusion references
• Prohibition of targeting minors
• Advertising may only promote licensed operators and products
• GGL (Gemeinsame Glücksspielbehörde der Länder) monitors compliance

The timing restrictions significantly limit influencer marketing opportunities, as most social media engagement occurs outside permitted hours. Influencers must also ensure promoted operators hold valid German licenses.

France: ANJ Oversight

Regulated

France permits gambling advertising including influencer marketing for licensed products (sports betting, poker, horse racing), but online casino remains prohibited. Key rules:

• Influencer content must comply with general advertising standards overseen by ANJ
• Clear disclosure of commercial relationships required
• Prohibition of targeting minors
• Responsible gambling messaging mandatory
• Cannot promote unlicensed operators or prohibited products (online casino)

ANJ has issued guidance on digital advertising compliance and monitors social media channels for violations. Promoting unlicensed operators carries significant penalties.

Lithuania: Upcoming Complete Ban

Complete Ban from July 2025

Lithuania will implement a comprehensive gambling advertising ban from July 2025, eliminating all influencer marketing opportunities. The legislation follows growing concern about gambling harm and mirrors approaches in Belgium and Italy.

Sweden: Spelinspektionen Approach

Regulated Market

Sweden permits gambling advertising including influencer marketing under specific conditions:

• Moderation requirement - advertising must not be "aggressive" or excessive
• Clear disclosure of commercial content
• Prohibition of targeting under-18s
• Responsible gambling messaging requirements
• Only licensed operators may be promoted

Spelinspektionen has issued fines against operators for advertising violations and monitors major streaming platforms for compliance.

Twitch and Casino Streaming

Twitch emerged as a major platform for gambling content through "casino streaming" - live broadcasts of slot play, table games, and other gambling activities. This practice attracted significant regulatory and platform attention.

Twitch's 2022 Policy Change

In October 2022, Twitch prohibited streaming of gambling sites that include slots, roulette, or dice games unlicensed in the US or other jurisdictions providing "sufficient consumer protection." This effectively banned promotion of crypto-casinos and offshore operators while permitting licensed gambling content.

This policy reduced but did not eliminate gambling streaming on Twitch. Streamers promoting EU-licensed operators generally remain compliant with Twitch rules but must still follow applicable national advertising regulations.

Compliance Considerations for Streamers

EU-based casino streamers or those targeting EU audiences face multiple compliance layers:

1. Platform Rules: Compliance with Twitch, YouTube, or other platform gambling policies
2. National Advertising Law: Rules of the streamer's country of residence
3. Target Audience Rules: Regulations applying where viewers are located
4. Operator License Conditions: Requirements imposed on the gambling operator

Streamers operating sponsored gambling content effectively function as advertising channels, triggering the same regulatory requirements that apply to affiliate marketers and traditional advertisers.

Disclosure and Transparency Requirements

Across all EU jurisdictions, proper disclosure of commercial relationships represents a fundamental compliance requirement for gambling influencer content.

What Must Be Disclosed

• Paid Partnerships: Direct payment from gambling operators for content
• Sponsored Bankrolls: "Demo" or "fun" money provided by operators for streaming
• Affiliate Relationships: Commission arrangements for referred players
• Free Access: VIP status, free bets, or other benefits provided by operators
• Brand Ambassadorships: Ongoing relationships with gambling companies

How to Disclose

Effective disclosure typically requires:

• Prominence: Disclosure visible before engagement with promotional content
• Clarity: Unambiguous language such as "Ad," "Sponsored," or "Paid Partnership"
• Consistency: Disclosure throughout the content, not just at the start
• Platform Features: Use of built-in disclosure tools where available (e.g., YouTube's paid promotion checkbox)

The European Advertising Standards Alliance (EASA) provides guidance on influencer marketing best practices that apply across member states.

Enforcement and Penalties

Enforcement of influencer marketing rules varies significantly across the EU, with some regulators actively pursuing cases while others focus primarily on operators.

Operator Liability

In most jurisdictions, gambling operators bear primary responsibility for influencer marketing conducted on their behalf. This includes:

• Contractual obligation to ensure influencer compliance
• Liability for unlawful advertising regardless of who creates content
• Risk to gambling license for advertising violations
• Financial penalties that can reach hundreds of thousands of euros

Our enforcement actions guide details how regulators pursue advertising violations and potential consequences for operators.

Influencer Liability

Influencer personal liability varies by jurisdiction:

• Consumer Protection Laws: Individual liability under UCPD for misleading commercial practices
• Tax Authorities: Undisclosed income from gambling promotion may trigger tax enforcement
• Platform Consequences: Account suspension or termination for policy violations
• Reputational Risk: Public regulatory action damages influencer credibility

Notable Enforcement Cases

Youth Protection Concerns

A central regulatory concern driving influencer marketing restrictions is the potential to normalize gambling among young people. Social media platforms skew toward younger demographics, and influencer content often reaches audiences below legal gambling age.

Research Findings

Academic research has documented concerning patterns:

• Young people frequently encounter gambling content on social media
• Parasocial relationships with influencers may increase receptivity to gambling promotion
• Gambling content often lacks clear commercial disclosure
• Win-focused content presents unrealistic gambling expectations

The GambleAware organization has published research on gambling advertising exposure among young people, contributing to evidence supporting regulatory action.

Age-Targeting Challenges

Unlike traditional broadcast media with established age-restriction mechanisms, social media platforms present significant age-targeting challenges:

• Age verification on platforms relies on self-declaration
• Algorithmic recommendation can push gambling content to young users
• Influencer audiences often span multiple age groups
• Organic sharing bypasses any targeting controls

These challenges inform rules like the Netherlands' requirement that advertising reach 95% adults aged 24+, a threshold difficult to achieve for most social media content.

Compliance Best Practices

Organizations engaging in influencer marketing for gambling must implement robust compliance frameworks.

For Operators

1. Jurisdictional Assessment: Identify all countries where influencer content will be accessible and applicable regulations
2. Contractual Requirements: Include specific compliance obligations in influencer agreements
3. Content Review: Pre-approve all promotional content before publication
4. Monitoring: Ongoing surveillance of influencer output for compliance
5. Training: Ensure influencers understand applicable requirements
6. Documentation: Maintain records demonstrating compliance efforts

Our Compliance Risk Assessor tool can help evaluate regulatory risk across different EU markets.

For Influencers

1. Know the Rules: Understand regulations in your country and target audience locations
2. Disclose Everything: Transparent disclosure of all commercial relationships
3. Verify Operators: Only promote operators licensed in relevant jurisdictions
4. Include Warnings: Add appropriate responsible gambling messaging
5. Document Agreements: Keep records of all sponsorship arrangements
6. Seek Advice: Consult legal counsel for significant sponsorship deals

Future Regulatory Trends

The regulatory trajectory for gambling influencer marketing in the EU points toward increasing restrictions:

• Advertising Bans Expanding: More countries considering Belgium/Italy-style comprehensive bans
• Platform Obligations: DSA and potential future legislation increasing platform responsibility
• Enforcement Intensification: Regulators developing expertise in monitoring digital channels
• Cross-Border Coordination: Growing cooperation between national authorities on enforcement
• Youth Protection Focus: Continued emphasis on preventing gambling normalization among young people

Operators and influencers should anticipate continued tightening of the regulatory environment and plan for markets where influencer marketing may become entirely prohibited.

Related Resources

For additional information on gambling advertising and marketing regulation in the EU:

• Gambling Advertising Bans and Restrictions in the EU – Comprehensive guide to advertising regulations by country
• Affiliate Marketing Rules for Gambling in the EU – Requirements for affiliate partnerships and commission arrangements
• Underage Gambling Prevention in the EU – Youth protection measures and age verification
• Problem Gambling Statistics and Prevention Measures – Public health context for advertising restrictions
• Responsible Gambling Operator Requirements – Technical standards for player protection
• EU Countries Gambling Regulations Index – Browse all country profiles

Last Updated: December 2025