First Pan-European Code for Responsible Advertising for Online Gambling published

The European Gaming & Betting Association has today (28 April 2020) announced publication of the first Pan-European Code For Responsible Advertising For Online Gambling (that you can download below). Its press release states as follows:

BRUSSELS, 28 April 2020 – The European Gaming and Betting Association (EGBA) has today published the first pan-European Code of Conduct for responsible advertising for online gambling. The Code is broad in scope and introduces essential standards for advertising content, across all media platforms, and dedicated measures for social media. The Code has a particular focus on minor protection.

The “Code of Conduct on Responsible Advertising for Online Gambling” intends to complement and strengthen existing legal and self-regulatory frameworks for online gambling advertising in Europe(1). The initiative has been developed in the context of the EU Audio Visual Media Services Directive, which emphasises the important role of self and co-regulation in protecting minors from exposure to gambling advertising(2).

The Code includes specific measures on:

  • Content moderation – how gambling advertising should and should not look like.
  • Minor protection – no gambling advertising during broadcasts dedicated to minors; age screening tools on social media to protect minors.
  • First-of-their-kind measures for social media marketing – age-gating on the social media profiles of gambling brands to ensure minors do not have access.
  • Pioneering measures for sponsorship arrangements – no sponsoring of activities which have a predominant appeal to minors.
  • Responsible gambling messaging and campaigns.

The Code applies to EGBA members and is open for signature by online gambling companies licensed in the EU/EEA and UK, other gambling associations and representation bodies of the media sector. It is EGBA’s intention to ensure that compliance with the Code is monitored and enforced by an independent third-party.

The Code sets long-term standards for gambling advertising content in Europe and complements EGBA’s more immediate efforts to promote responsible gambling advertising during the coronavirus.

“We’re very pleased to present EGBA’s Code of Conduct for responsible gambling advertising, which promotes high standards for minor protection and socially responsible advertising content. Advertising is essential to inform the consumer of the websites which are regulated and steer them away from rogue black-market websites. But advertising should be responsible and protect consumers, particularly minors. We encourage other gambling companies to sign up to the Code and look forward to engaging with Europe’s authorities to ensure its success.” – Maarten Haijer, Secretary General (EGBA).

EGBA has mandated a third-party to assess the impact of the Code on existing national regulations and self-regulation and a summary of this analysis will be published on EGBA’s website at the beginning of May 2020.

Of relevance for gambling operators and their marketing affiliates alike, the “Scope” section of the Code document states as follows:

The Code is intended to be applicable in all EU, EEA countries and the UK. Signatory parties agree to comply with the measures included in this Code. The Code covers all Gambling marketing activities in all media platforms (including television, radio, social networks and other online platforms), regardless of the technology used. All signatories, commit to implement and uphold, in letter and in spirit, this Code of Conduct.

Online gambling operators should seek to ensure their Advertising intermediaries and/or Affiliates are aware and comply with the EGBA Code, where applicable. This is without prejudice to any liability the Affiliates and/or Advertising intermediaries may incur through their own behaviour. However, if an Online gambling operator is aware that an advertising intermediary and/or affiliate is in breach of the Code, the Online gambling operator should take appropriate steps to ensure that the advertising intermediary ceases such behaviour.

Signatory parties may promote the Code where appropriate, including on their websites or via other channels. The Code is a “living document” and can be updated by EGBA, in consultation with the signatory parties, in the future.

EGBA has also published the following FAQ in relation to its Code of Conduct on Responsible Advertising for Online Gambling:

Question & Answers

Whose initiative is the Code of Conduct?

The advertising Code of Conduct (referred to as the “Code”) is an initiative of the European Gaming and Betting Association (EGBA). EGBA is the Brussels-based trade association representing the leading online gaming and betting operators established, licensed and regulated within the EU (and UK). These are bet365, Betsson Group, GVC Holdings Plc, Kindred Group Plc, and William Hill Plc. EGBA members accounted for 25% of Europe’s online gambling revenue in 2018 and together have more than 16.5 million customers in Europe.

What is the objective of the Code?

The objective of the Code is to enhance consumer and minor protection through the promotion of responsible advertising measures for online gambling. The Code reflects EGBA’s commitment to ensuring that gambling is a safe and responsible entertainment pastime. The Code sets long-term standards for gambling advertising content in Europe and complements EGBA’s more immediate efforts to promote responsible gambling advertising during the coronavirus.

What is the scope of the Code?

The Code applies to all EGBA members, is open for signature by gambling operators, other gambling associations and representation bodies of the media sector. The Code is applicable in all EU/EEA countries and the UK and covers all types of advertising for online gambling across all types of media platforms, regardless of the technology used.

What type of measures are proposed in the Code?

The Code includes social responsibility measures and best practices for online gambling advertising including rules for content moderation, specific measures on minor protection, sponsorship, responsible gambling messaging and campaigns, and first-of-their-kind gambling advertising measures for social media.

How will the Code be applied?

The Code applies to all signatory online gambling companies and their contracted affiliates and advertising intermediaries, such as influencers, brand ambassadors, etc, where applicable. EGBA endeavours to ensure that compliance with the provisions of this Code, by its signatories, is monitored regularly in a transparent, participative and accountable manner by an independent third-party.

How long does the Code apply?

The Code has unlimited duration and is subject to updates of its terms.

How will the success of the Code be assessed?

EGBA has commissioned a third-party analysis of the impact of the Code on existing regulatory and self-regulatory advertising measures in 14 EU countries and the UK. A summary of this analysis will be published on EGBA’s website at the beginning of May 2020.


1. You can download below EGBA’s Spring 2020 edition of “Online Gambling Focus” that contains an article on the above topic entitled “Leading the way in standards for responsible advertising”.

2. On 15 May 2020, EGBA published its above-mentioned analysis under the heading “New Analysis Shows EGBA’s Responsible Advertising Code Can Reinforce National Advertising Rules”, an Executive Summary of which you can download below. Its accompanying press release reads as follows:

The European Advertising Standards Alliance (EASA)[1], was mandated by EGBA to conduct a gap analysis exercise, to assess how the new EGBA Code of Conduct on Responsible Advertising for Online Gambling fits in comparison with the applicable regulatory and self-regulatory advertising rules in 15 selected European countries.[2]

The EASA analysis found that the measures introduced by EGBA’s Code are broadly consistent and congruent with national requirements on gambling advertising. In some of the countries, the Code was even found to be overall stricter than the applicable national provisions, with certain parts of the Code considered to be more specific in nature.

EGBA believes the Code can, therefore, reinforce and strengthen existing national regulations for online gambling advertising in European countries. EGBA’s members are already applying the Code’s measures in addition to applicable advertising regulations in the European countries they operate in. The analysis found the Code could be already implemented in 9 of 15 countries reviewed, if local self-regulations were amended to include the provisions of EGBA’s Code.

EGBA intends for the Code to be monitored and enforced by an independent third party. To maximise the potential of the Code, EGBA invites eligible[3] online gambling companies to sign the Code and encourages national online gambling associations to endorse and promote the Code to their members.

“This initial analysis demonstrates how EGBA’s Code can already strengthen responsible advertising measures in a number of European countries. We’re very pleased that EGBA members are committed to apply the Code and demonstrate their commitment to responsible advertising. With its dedicated measures for social media and minor protection, the Code will drive industry standards for responsible advertising and help strengthen consumer protection for European citizens.” – Maarten Haijer, Secretary General.

A summary of EASA’s gap analysis can be found here and some important extracts are below.[4] 


  • 13 countries have general and not gambling-specific advertising self-regulatory requirements covering all online media platforms.
  • Regulations and self-regulation co-exist in 12 countries, while 3 countries do not have any specific self-regulatory measures on gambling.
  • EGBA’s Code could be implemented in 9 of 15 countries, if local self-regulations were amended to include the provisions of EGBA’s Code.

Minor protection

  • Only 6 countries have specific legislative rules for protecting minors from viewing gambling advertisements, while in 5 countries there are no legislative or specific self-regulatory rules on gambling advertising to protect minors. EGBA’s Code includes dedicated rules, which, in these countries, could benefit the frameworks for the protection of minors.

Social media

  • 13 out of the 15 countries reviewed have no specific requirements for gambling advertising on social media. In this sense, EGBA’s Code can provide a detailed set of measures dedicated for social media.


  • 11 countries do not have any dedicated measures for sponsorship. EGBA’s Code includes a dedicated chapter on sponsorship.

Responsible gambling messaging

  • Responsible gambling messaging is not required in 5 countries. EGBA’s Code outlines the obligation for advertisements to carry responsible gambling messages, wherever possible, and foresees the possibility of organising responsible gambling campaigns.

Customer complaints

  • Most customer complains about gambling advertising concern bonuses and portrayal of gambling, both issues addressed in EGBA’s Code.

[1] EGBA consulted with EASA for advice on its Code but this in no way implies that EASA or its members endorse the Code in any form, which remains under EGBA’s responsibility.

[2] Belgium, Greece, Poland, Bulgaria, Hungary, Romania, Czech Republic, Ireland, Spain, France, Italy, Sweden, Germany, Netherlands, United Kingdom.

[3] Companies who are licensed in the EU, EEA countries or the UK.

[4] Individual countries are not identified in the publicly available summary.