UK LEGAL


8. any cross-selling of products, 9. all direct marketing even with ‘opt in’, and


10. inducements such as free bets and free spins.


In addition, the APPG recommends a statutory duty on online platforms to ensure under 18s are not exposed to gambling advertising, and work with social media companies to prevent illegal operators advertising to UK consumers. Taken together, these measures would amount to a comprehensive suppression of the right for licensed operators to advertise gambling in Great Britain.


consumers can access unlicensed products. It is vital, then, that as a product becomes more restricted there are strong incentives on suppliers to become and remain regulated. Our regulatory system uses the tried and tested method of the carrot and the stick. The stick, of course, is the threat of prosecution for unregulated supply. Given the overseas and often anonymous nature of unlicensed online suppliers of gambling services, it often proves ineffective. The carrot is the right to advertise. Advertising is one of the few meaningful competitive advantages enjoyed by regulated operators. What the APPG fails to address in its report is the risk that, if advertising permissions are eroded beyond a certain point, there is no longer a sufficient incentive for gambling operators to take on the growing costs and compliance burden associated with operating lawfully.


WHAT IS THE APPG RECOMMENDING? The report sets out a number of recommendations, which include a ban on: 1. all gambling advertising before 9pm, including online,


2. gambling sponsorship in sport, except in horse and greyhound racing,


3. gambling sponsorship of TV and radio shows,


4. gambling related ‘content’ marketing, 5. promotion of gambling by ‘influencers’ and ‘content creators’ on social media and streaming platforms,


6. any gambling advertising in video games with a PEGI rating of lower than 18,


7. all advertising of the ‘most harmful’ form of gambling products online,


MAY 2026 21


ARE THE RECOMMENDATIONS LIKELY TO BE ADOPTED? There is no obligation on the Government to adopt the APPG’s recommendations. Despite the numerous regulatory reforms of the White Paper and recent significant tax increases, advertising has remained largely untouched by the Government. This is likely deliberate. The Government likely recognises the essential role of the right to advertise in our regulatory system and will appreciate that if all of the APPG’s proposed measures were adopted, this would seriously undermine the incentive on operators to be licensed and regulated by the Gambling Commission. The APPG provides examples from a number of European jurisdictions that it feels the UK is falling behind when it comes to advertising restrictions. Whilst it is true that some European jurisdictions have adopted more restrictive rules on gambling advertising, the report fails to discuss the impact of these restrictive measures. For example, the report cites the ‘stringent restrictions’ adopted by the Netherlands, but fails to mention that by its regulator’s own estimates, less than half that country’s GGR now goes to the licensed market.


Many of the proposed measures would only affect licensed operators, for example it would be extremely difficult to prevent unlicensed operators sending direct


Melanie is a gambling regulatory lawyer with 13 years’ experience in the sector. Melanie advises on all aspects of gambling law including licence applications, compliance, advertising, licence reviews and changes of control. She has acted for a wide range of gambling operators including major online and land-based bookmakers and casinos, B2B game and software suppliers and start-ups. She also frequently advises operators of raffles, prize competitions, free draws and social gaming products. Melanie has a particular interest in the use of new technology for gambling products and novel product ideas.


marketing emails to UK customers or offering free bets, or to prevent overseas-based influencers from continuing to promote unlicensed operators.


The Government is also likely to note that, while majority of the report’s recommendations are framed around protecting children and young people, licensed operators already have strict age verification measures in place to prevent under 18s from gambling. The Gambling Commission’s data has not shown an increase in underage people taking part in gambling, despite the ever increasing advertising spend by operators highlighted in the report. It seems unlikely, therefore, that the proposed measures would have any significant impact on reducing gambling by children and young people.


The potential benefits of the APPG’s recommendations appear limited, particularly when set against the very real risk of reduced channelisation to the licensed market. Nevertheless, while further significant gambling reforms are unlikely, over time we may well see incremental tightening of advertising permissions, particularly in politically sensitive areas such as influencer marketing and sports sponsorship.


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