ADVERTISING AND MARKETING
rules. The report authored in 2024 by Dr Raffaello Rossi and his colleagues at the University of Bristol found that whilst all the paid-for ads they studied adhered to AGA regulations stipulating the inclusion of safer gaming messages and help hotlines, only 25 percent of organic ads adhere to the codes. 10 This meant that, over the period of the study which was only a single week, there were over 1000 pieces of content marketing from major casino and sports betting brands which contravened advertising codes. Faced with a similar wave of influencer marketing promoting legal gambling platforms in Norway, the regulator successfully disrupted it using a tried and tested approach. Speaking at the IMGL conference in Lisbon, Trude Høgseth Felde, Senior Advisor to the Norwegian Gaming Authority related her organization’s dealings with Kapow.com, an influencer collective. “This was a group of influencers that collaborated to form a super affiliate site, kapow.com. They each had individual followers. They recruited new followers, and they were all aiming to reach our youngest. They went partying, they went on exotic travels, expensive cars, gambling. There were celebrities and sports stars creating big stories and of course, this plays with young people’s fear of not being part of the community, the fear of missing out. Having identified the activities of the group, we sent out a notice and we also threatened action against their clients. Surprisingly, two hours after our notice went out, the website closed down, and we received emails from each and every one of the individual influencers that they would delete all the content and stop their activities. In some cases they had no idea that what they were doing was illegal and just informing them was enough to persuade them to stop.” Another speaker on the same panel agreed. “Influencer marketing in gambling needs rules, but the same applies in pharmaceutical products, in high sugar products and many
other areas. There are already laws in place covering promotion of these things: what we’re lacking is enforcement. So, before we talk about further restrictions on the regulated market, we need to enforce the current law. In my country of Portugal, nobody has been arrested for promoting illegal gambling even though it’s crime. Influencers have an important role in educating the consumer. “The mission of regulators in Europe is to provide a regulated framework for operators, to protect the consumer and to generate tax revenue for the state. In many cases we have the legal framework we need to achieve that so we should start with enforcement rather than greater regulation.” For some, the scale of the challenge is overwhelming. There are so many pieces of content being created and circulated that monitoring it and mounting an effective response is beyond the scope of advertising standards bodies established in different times. Influencer marketing, alongside other new marketing methods, requires a modern response to regulation. Programmed well, AI can be the regulator’s friend here. It can identify content which breaches advertising codes and even send automatic cease and desist notices leaving the regulator to focus only on persistent offenders. Under many legal regimes, operators who commission marketing are responsible for its content. The European Gaming and Betting Association’s (EGBA) recent launch of an industry-wide pledge “establishes enhanced standards for transparency, the protection of minors, and independent monitoring for influencer marketing in Europe’s gambling sector”, according to the organization. 11 Regulating influencer marketing in the unregulated market As the Norwegian experience above shows, when influencers were informed their actions were illegal, they didn’t stop influencing, they just moderated their behaviour. In many
10 https://www.bristol.ac.uk/media-library/sites/business-school/documents/Bristol_SM_Research_Report.pdf 11 https://www.egba.eu/uploads/2025/10/251020-Responsible-Influencer-Marketing-in-Online-Gambling-1.pdf
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IMGL MAGAZINE | DECEMBER 2025
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