Can Influencers Promote Online Casinos? Gambling Influencer Rules by Country (2026)
Can Influencers Promote Online Casinos? Gambling Influencer Rules by Country
TL;DR: Regulators now pursue the creator, not only the operator. Germany’s GGL served a €250,000 penalty on a rapper over casino streams in April 2026, Italy’s AGCOM had fined creators about €2M under its total ad ban by November 2024, and Brazil ordered 937 influencer pages removed between January 2025 and June 2026. In the UK the operator carries the liability for the influencers it contracts, and an account with 100,000+ under-18 followers is “indicative of strong appeal”, which rules the post out.
Primores’ iGaming package pairs Telegram Ads, landed in a bot, channel or mini-app, with organic content localized per market; the rules below decide which markets either can run in: iGaming traffic.
⚠️ Read 2026-11-09/10. Not legal advice. Most rows rest on law-firm articles and named-data trade press, not the statute or the regulator’s own page. Each row says which. Brazil’s Ordinance 73/2026 was not read in the official gazette, the GGL and KSA pages were not fetched, no Baltic statute was read, and whether Spain’s law restoring the annulled articles has passed was not found. The platform-side rules (TikTok, YouTube, Instagram) are on marketing/gambling-content-platform-rules.
Who is liable, market by market
| Market | Can an influencer promote a licensed operator? | Who carries the liability | Enforcement on record | Verification |
|---|---|---|---|---|
| UK | Yes, within CAP/BCAP rules | The licensed operator, for every third party it contracts (UKGC SR code 1.1.2); the ASA rules on the ad itself | ASA rulings against posts with “strong appeal” to under-18s | CAP guidance: primary read. UKGC code: partial |
| Italy | No. Total ban on gambling advertising (Art. 9, DL 87/2018) | The account holder, personally | About €2M in creator fines by Nov 2024; fine set at 20% of the ad’s value, minimum €50k per violation | Trade press, primary read of the article |
| Spain | Yes for now: the celebrity, video-platform and social-network articles of RD 958/2020 were annulled | Operator under the rest of the decree | Supreme Court ruling of 10 Apr 2024 | Primary read (court press release) |
| Germany | Only for licensed gambling; advertising unlicensed gambling is banned (GlüStV 2021 § 5(7)) | The performer too | €250,000 penalty plus cease-and-desist on Capital Bra (TikTok, Twitch, an affiliate site), served 18 Apr 2026 | Trade press, primary read of the article |
| Netherlands | Not as a role model. Online ads allowed only if the operator proves 95%+ of the audience is 24 or older | Operator burden of proof | Untargeted-ad ban since 1 Jul 2023 | Law firm, primary read of the article |
| Brazil | Only for operators on the Ministry of Finance’s authorized list | Operator for the influencers it hires (Ordinance 1.231/2024); since 10 Jul 2026 the influencer must also verify the operator first | 937 influencer pages ordered removed, Jan 2025–Jun 2026 | Ministry page: primary read. Ordinance 73/2026: law firm |
| Lithuania | Only betting ads are allowed online, and they may not link to betting sites | Not stated in the source | Full ban planned for 2028 | Public broadcaster, primary read |
UK: the operator answers for the influencer
The UK Gambling Commission does not license affiliates. Instead, “Licensees are responsible for the actions of third parties with whom they contract”, under Social Responsibility code 1.1.2. The ASA then rules on the post itself.
Three tests apply to an influencer post, per the ASA’s 2023 guidance:
- no “strong appeal” to under-18s;
- not “advertised directly to under-18s”;
- no under-25s, or people who look under 25, in a significant role.
In October 2025 CAP and BCAP added a rule of thumb for the first test: an account with 100,000 or more under-18 followers across platforms is “indicative of strong appeal”. It is not a hard cut-off. Law-firm readings of the same update put football in the inherent strong-appeal group, with rugby, cricket and tennis lower risk.
Our read: a UK service needs the creator’s under-18 follower count across every platform before the deal, not after the post.
Italy: no market for gambling promotion
Italy’s ban covers all gambling advertising, and AGCOM applies it to individual accounts on TikTok, YouTube, Instagram, Facebook, X and Twitch. At its September and October 2024 sessions it adopted 21 new sanctions, bringing creator fines since July 2024 to about €2M. The law sets the fine at 20% of the ad’s value, with a minimum of €50,000 per violation, and the regional administrative court (TAR Lazio) upheld the fines.
A Constitutional Court ruling of 20 October 2026 (172/2026) reportedly found the fixed €50,000 minimum unconstitutional where it is “manifestly disproportionate”, while leaving the ban in place. That rests on a single trade source; the ruling itself was not read.
Spain: an open gap that is meant to close
On 10 April 2024 the Supreme Court annulled several articles of Royal Decree 958/2020 for lack of legal backing:
- Art. 13.1 and 13.3 (new-customer promotions);
- Art. 15 (“personajes famosos”, famous people);
- Art. 23.1 (the general ban via information-society services);
- Art. 25.3 (video-sharing platforms);
- Art. 26.2 and 26.3 (social networks).
The rest of the decree stands. The Ministry of Consumer Affairs has pushed a law to restore the annulled articles; we found no confirmation that it has passed. Our read: plans built on the gap can end with one vote.
Germany: the GGL serves the performer
Germany’s 2021 State Treaty bans advertising for unlicensed gambling, and the joint regulator, the GGL, now pursues individual streamers. It opened proceedings against the rapper Capital Bra in October 2025, issued a €250,000 penalty notice plus a cease-and-desist order, and with police help served it at his Wiesbaden concert on 18 April 2026. The channels named were TikTok (2.3M followers), Twitch and an affiliate site.
Netherlands: no role models, and the operator must prove the audience age
Since 1 July 2023 untargeted gambling advertising is banned. Online and social ads are allowed only if the operator “actively prevents” them reaching under-24s and can prove at least 95% of the ads reach people aged 24 or older. Operators must also exclude people on the CRUKS self-exclusion register. A separate role-model ban, covering celebrities, footballers and influencers, has applied to licensed operators since June 2022 (law-firm and trade-press reports; the regulator’s page was not read).
Brazil: verify the operator before the contract
Brazil regulates both sides of the deal:
- Operator liability. Under Ordinance SPA/MF 1.231/2024, operators may be held liable for abusive or misleading ads by “influenciadores contratados por eles” (influencers they hire).
- Influencer duties (Ordinance 73/2026, effective 10 Jul 2026). Influencers must check that an operator is authorized before taking the deal and keep its tax number (CNPJ). The rules also ban promoting unlicensed operators through “códigos promocionais” (promo codes) and “mecanismos de afiliação” (affiliation mechanisms). Ordinance 1.964/2026 requires a warning on at least 10% of the ad from 17 July 2026.
- Enforcement. The Ministry of Finance ordered 937 influencer pages removed between January 2025 and June 2026. Of those, 803 promoted unauthorized operators and 134 broke regulated-market rules. It also notes irregular campaigns continuing on WhatsApp and Telegram.
The Senate inquiry (CPI das Bets) did not indict anyone: its report was rejected on 12 June 2025.
Lithuania
Since 1 July 2025 only betting ads are allowed, capped at 15 seconds with frequency limits. Online betting ads may not link to betting sites, and a full ban is planned for 2028. The source does not mention influencers.
What this means for an iGaming content plan
Our read, drawn from the table:
- Liability now reaches the creator in Italy, Germany and Brazil. A plan that leaves compliance to the operator leaves the account holder exposed.
- A licence in the target market is necessary and not sufficient. Italy has no legal route at all, and the UK and the Netherlands add audience-age tests that a creator’s follower base can fail.
- Promo codes and affiliate links are the enforcement target in Brazil, and the regulator watches the move to WhatsApp and Telegram. The off-platform route is visible.
- Fragile gaps (Spain’s annulled articles, Italy’s softened minimum fine) are not foundations to build a channel on.
FAQ
Is it legal for influencers to promote online casinos in the UK?
Yes, for a licensed operator and within CAP rules: no strong appeal to under-18s (100,000+ under-18 followers indicates strong appeal), nothing aimed at under-18s, and no under-25s in significant roles. The operator is responsible for the influencers it contracts.
Can influencers advertise gambling in Italy?
No. Italy bans all gambling advertising, and AGCOM fines individual creators, about €2M in total by November 2024.
Can influencers promote betting in Spain?
The Supreme Court annulled the decree’s celebrity, video-platform and social-network articles in April 2024, so those limits are not in force. The government has said it will restore them by law, and the rest of the decree still applies.
Are gambling streamers fined in Germany?
Yes. The GGL served a €250,000 penalty on a rapper over casino streams on TikTok and Twitch in April 2026, for advertising unlicensed gambling.
What are Brazil’s 2026 rules for betting influencers and promo codes?
Since 10 July 2026 influencers must verify that an operator is authorized before taking a deal, and promo codes and affiliation mechanisms for unlicensed operators are banned. Operators remain liable for the influencers they hire.
Can you advertise betting online in Lithuania?
Only betting ads, with time and frequency caps, and they may not link to betting sites. A full ban is planned for 2028.
Who is liable for an influencer’s gambling post, the operator or the influencer?
Both, increasingly. The UK puts it on the operator, Brazil on both, and Italy and Germany pursue the creator directly.
Do not cite
| Claim | Why not |
|---|---|
| ”Spain bans celebrity, influencer and social-network gambling ads” | Annulled on 10 Apr 2024 |
| ”AGCOM’s €50k fine is a fixed floor” | Ruling 172/2026 reportedly requires lower fines where it is manifestly disproportionate (single trade source) |
| “100,000 under-18 followers is a hard UK limit” | CAP calls it “indicative of strong appeal”, not a cut-off |
| ”The CPI das Bets indicted influencers” | The report was rejected on 12 Jun 2025 |
| ”Brazil removed 324 influencer profiles” | A 2025 snapshot, superseded by 937 pages (Jan 2025–Jun 2026) |
| “AGCOM fined Meta €1.3M” | Conflicting headlines; unresolved |
Key Takeaways
- Italy, Germany and Brazil act against the creator personally; the UK puts liability on the operator for the influencers it contracts.
- UK: 100,000+ under-18 followers across platforms indicates strong appeal; no under-25s in significant roles.
- Netherlands: online gambling ads need proof that 95%+ of the audience is 24 or older.
- Brazil: verify the operator’s authorization before the deal; no promo codes or affiliation for unlicensed operators.
- Our read: a licence is the entry ticket, not the whole compliance plan.
Related
- marketing/gambling-content-platform-rules
- marketing/telegram-marketing-channel
- marketing/alternative-ad-channels
- glossary/ftc-ai-marketing-enforcement
Sources
- UK Gambling Commission, LCCP SR code 1.1.2 — licensees responsible for contracted third parties. Tier 1, Partial (official-page snippet).
- ASA/CAP, updated guidance on protecting under-18s (14 Oct 2025) — 100,000+ under-18 followers as indicative of strong appeal. Tier 1, Primary read.
- ASA, Influencing your choice of influencer (23 Mar 2023) — strong-appeal, under-18 targeting and under-25 rules. Tier 1, Primary read.
- Osborne Clarke on the CAP update (Oct 2025) — football inherently strong appeal; rugby, cricket, tennis lower risk. Tier 2, Secondary.
- AGIMEG, AGCOM creator sanctions (7 Nov 2024) — 21 sanctions, about €2M, 20% of value with €50k minimum, TAR Lazio upheld. Tier 2, Primary read.
- PalAI on Constitutional Court ruling 172/2026 — fixed minimum unconstitutional where manifestly disproportionate. Tier 2, Secondary (ruling not read).
- Poder Judicial, Supreme Court annuls parts of RD 958/2020 (10 Apr 2024) — annulled articles. Tier 1, Primary read.
- Intergame, GGL €250k penalty on Capital Bra (21 Apr 2026) — penalty, channels, service on 18 Apr 2026. Tier 2, Primary read.
- CMS, Dutch ban on untargeted online gambling ads (26 Apr 2023) — 95% 24+ proof, CRUKS. Tier 2, Primary read.
- Ministério da Fazenda, Ordinance SPA/MF 1.231/2024 (updated 27 Oct 2026) — operator liability for hired influencers. Tier 1, Primary read.
- Cescon Barrieu, new betting ordinances (17 Jul 2026) — Ordinance 73/2026 influencer duties, promo-code and affiliation ban, 10% warning. Tier 2, Primary read.
- FocusGN, 937 influencer pages removed (29 Jul 2026) — removal count and split; WhatsApp and Telegram. Tier 2, Primary read.
- TNH1, CPI das Bets rejects indictments (Jun 2025) — report rejected 12 Jun 2025. Tier 2, Secondary.
- LRT, Lithuania begins gradual ban on gambling advertising (1 Jul 2025) — betting-only ads, no links, 2028 ban. Tier 2, Primary read.