Regulation for online betting and gambling (“gaming” in the USA) is specific to each jurisdiction. In Europe, there are notably no specific EU-level requirements as Member States have guarded jealously their autonomy in this area, often to protect state-run lotteries.
In the UK, the Gambling Commission is a proactive regulator, implementing the Gambling Act 2005 which states “A person commits an offence if he invites, causes or permits a child (<16) or young person (<18) to gamble.”
There are three licensing objectives which support the whole basis of gambling regulation. The third states that “children and other vulnerable persons should be protected from harm or exploitation from gambling.”
The Licence Conditions Codes of Practice (LCCP) set out the regulations more specifically.
The Remote gambling Social Responsibility Code, section 3.2.11, states
Licensees must have and put into effect policies and procedures designed to prevent underage gambling and monitor the effectiveness of these.
Such procedures must include:
- Verifying the age of a customer before the customer is able to:
- deposit any funds into their account;
- access any free-to-play versions of gambling games that the licensee may make available; or
- gamble with the licensee using either their own money or any free bet or bonus.
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warning potential customers that underage gambling is an offence;
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regularly reviewing their age verification systems and implementing all reasonable improvements that may be made as technology advances and as information improves;
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ensuring that relevant staff are properly trained in the use of their age verification procedures; in particular customer services staff must be appropriately trained in the use of secondary forms of identification when initial verification procedures fail to prove that an individual is of legal age; and
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enabling their gambling websites to permit filtering software to be used by adults (such as parents or within schools) in order to restrict access to relevant pages of those sites.
Compliance with these is a condition of licences; therefore any breach of them by an operator may lead the Commission to review the operator’s licence with a view to suspension, revocation or the imposition of a financial penalty and would also expose the operator to the risk of prosecution.
Advertising
Under the UK Committee of Advertising Practice Code, gambling advertisers must take active steps to prevent children and young people from seeing gambling ads. The requirements are specific and enforceable through the Advertising Standards Authority.
The key obligations are as follows:
Audience targeting and placement
Gambling ads must not be directed at children or young people, either intentionally or by likely effect.
• Ads must not be placed in media where children make up more than 25% of the audience
• Advertisers must use all available audience data to minimise under-18 exposure
• Contextual placement that is likely to appeal to children is prohibited even if audience data is incomplete
This applies across TV, online video, social media, display advertising, search, and influencer marketing.
Use of age targeting and age-gating tools
Where platforms offer age-targeting or age-gating tools, advertisers are required to use them.
• Social and video platforms must be configured to exclude under-18s
• Interest-based targeting must not be used where it risks proxy targeting of children
• Advertisers are responsible for ensuring their agency and platform settings are correctly applied
Failure to use available tools has repeatedly been treated by the ASA as a breach in itself.
Content rules designed to avoid child appeal
Even where targeting is correct, the ad content must not be of strong appeal to children.
• No use of characters, imagery, humour, or themes likely to appeal to under-18s
• No association with youth culture, video games, cartoons, or child-centred activities
• No depiction of gambling as a rite of passage or part of growing up
This is assessed objectively by the ASA, not by advertiser intent.
Strong restrictions on sports-related gambling ads
Because of youth exposure risks, gambling advertising around sport is tightly constrained.
• Ads must not be placed in media primarily aimed at under-18s even if sport-related
• Sports personalities with strong youth appeal must not be used
• Gambling must not be presented as integral to watching or enjoying sport
Additional voluntary measures such as the whistle-to-whistle ban on gambling ads during live games sit alongside the CAP Code.
No reliance on warnings alone
The CAP Code is explicit that warnings are not a substitute for proper targeting.
• “18+” labels and responsible gambling messages are mandatory
• They do not cure poor placement or targeting
• Advertisers cannot rely on disclaimers to offset child exposure
Responsibility sits with the advertiser
Crucially, CAP places responsibility on the advertiser, not the platform or publisher.
• Advertisers must take reasonable steps to exclude children
• Platform defaults or algorithmic delivery are not an excuse
• Repeated failures can lead to enhanced monitoring or referral to statutory regulators