How gambling operators are expected to keep marketing away from under-18s and vulnerable people

Why this is a distinct compliance area

Much of the coverage of gambling marketing focuses on sponsorship deals or campaign launches. Less visible, but arguably more important from a compliance standpoint, is the ongoing operational work operators and their marketing teams do to stop adverts reaching people who are under 18 or who may be vulnerable to gambling harm. This sits at the intersection of the Gambling Commission’s licence conditions, the advertising codes overseen by the Advertising Standards Authority (ASA), and an operator’s own internal marketing sign-off process.

It is not a single rule but a layered system: legal age limits, content standards, media placement restrictions, targeting controls on digital platforms, and ongoing monitoring. Understanding how the layers fit together explains why a single misplaced ad or an ill-judged influencer post can trigger regulatory action even when it was not deliberate.

The legal baseline: who counts as under-18 or vulnerable

Gambling is restricted to adults, and marketing rules exist to stop advertising content or placement from appealing to, or reaching, people below that age. Separately, the concept of a ‘vulnerable person’ in gambling regulation is broader than age. It can include people experiencing financial difficulty, mental health problems, or those who have self-excluded or shown signs of problem gambling. Operators are expected to build systems that consider both groups, not just the legal minimum age.

The Gambling Commission’s Licence Conditions and Codes of Practice (LCCP) require operators to ensure marketing is conducted in a socially responsible manner, and this obligation runs alongside advertising-specific rules set by the ASA and its sister body, the Committee of Advertising Practice (CAP), which writes the UK Advertising Codes.

Content standards: what an advert can and cannot do

The CAP and BCAP Codes (covering non-broadcast and broadcast advertising respectively) set out content rules that apply specifically to gambling marketing. Broadly, these prevent adverts from:

• Suggesting that gambling can solve financial problems, enhance social or sexual success, or is a rite of passage.
• Featuring content, imagery, language or humour that is likely to appeal particularly to under-18s, such as characters, styles or references associated with youth culture.
• Depicting anyone who is, or appears to be, under 18 taking part in gambling, or playing a significant role in an ad.
• Implying that gambling is a way to deal with personal, professional or financial problems.

These rules apply regardless of where the ad appears, from television and print through to social media posts and affiliate content. Operators are also expected to include responsible gambling messaging and signposting to support services as a standard part of marketing output, not as an afterthought.

Placement rules: keeping ads out of the wrong spaces

Beyond content, there are placement restrictions designed to reduce the chance of gambling ads reaching under-18 audiences. This includes rules on broadcast scheduling around programmes likely to have a significant child audience, and requirements for online platforms to use audience-targeting tools so that gambling ads are not served to users who are, or are likely to be, under 18. Programmatic and social advertising in particular relies on demographic and interest-based targeting data, so operators and their media buyers are expected to configure campaigns to exclude under-18 segments as far as the platform’s tools allow, and to monitor performance data for signs that this is not working.

For affiliates and influencers, the same standards apply even though the content may not originate directly from the operator. Regulators have made clear that operators remain responsible for marketing carried out on their behalf, which is why affiliate agreements typically include compliance clauses, content approval processes and audits.

Vulnerability: a harder problem to design around

Age can, in principle, be checked or inferred from data. Vulnerability is more difficult to detect from the outside, which is why the emphasis shifts towards tone, content and targeting practices rather than trying to identify individuals. Operators are expected to avoid marketing tactics that could exploit vulnerability, such as urgency-driven promotions, imagery suggesting guaranteed wins, or reactivation campaigns aimed at customers who have previously shown signs of harm or who have self-excluded.

Where an operator holds data suggesting a customer is struggling, for example through affordability checks or account monitoring, that customer would normally be excluded from further promotional marketing rather than targeted with incentives to keep playing.

What good compliance looks like in practice

In practice, a well-run marketing compliance function typically includes:

• A sign-off process for all marketing content, checking it against the CAP and BCAP Codes before publication.
• Exclusion lists and suppression rules so self-excluded or at-risk customers do not receive promotional communications.
• Ongoing due diligence and monitoring of affiliate and influencer content.
• Use of platform-level age and interest targeting controls, reviewed periodically rather than set once and forgotten.
• Staff training so marketing teams understand both the letter and the intent of the rules.

Because the underlying codes, technology and platform tools change over time, operators need to treat this as a continuous compliance exercise rather than a one-off checklist, and should check current requirements directly with the regulators rather than relying on past practice.

Where to check current requirements

Given how often codes and guidance are updated, operators and readers should always check the primary sources directly rather than relying on secondary summaries.