Key Takeaways
- The House of Lords Liaison Committee recommended “a comprehensive ban on gambling advertising” on 17 September 2026, and set out a narrower package for the UK government to adopt if a full ban is refused.
- The narrower package is the expensive one, because it would end direct marketing by operators and affiliates, inducement advertising including the words “free bet”, and all social media content marketing.
- Dutch regulator figures published on 16 April 2026 put licensed online revenue down 18% across 2025, with 47% of gambling spend going to illegal operators while 91% of players stayed with licensed sites.
- Operators should be pricing each acquisition channel against each restriction scenario now, since the measured effect sizes the committee relied on are published and can be applied to an operator’s own numbers.
What did the House of Lords actually recommend?
The committee recommended a full ban on gambling advertising in Great Britain, then set out a narrower package for the government to adopt if it will not go that far. The report is Gambling Harm: Time for Action: Follow-up report, HL Paper 52, published by the House of Lords Liaison Committee on 17 September 2026 under Lord Ponsonby of Shulbrede, revisiting the 2020 Select Committee report of the same name. [1]
At paragraphs 366 to 372 the committee argues for a precautionary model built on the principle that gambling should be tolerated but not promoted, and tells the government to make sure it holds the legal powers to impose a ban if it chooses to. [1] Paragraph 372 is the part most operators skipped on the day. If the government rejects a full ban, or phases one in, the committee wants targeted restrictions on content marketing, on direct marketing, and on advertising and sponsorship in sport, each independently evaluated for its effect on gambling harm and on the illegal market. [1]
Underneath that sits a structural change, since the committee wants gambling advertising regulated by the Gambling Commission on a statutory footing rather than by the Advertising Standards Authority, which alters who an operator answers to as well as what it may say. On-course advertising for horseracing and greyhound racing would be exempt. [1]
Which restrictions would cost the most revenue?
Direct marketing and inducements, not television. The narrower package reads mild next to a full ban, and for an online business it is not.
- Paragraphs 684 to 687 would ban direct marketing by operators and by affiliates, leaving only essential messages such as account information and harm interventions. [1]
- Paragraphs 622 and 635 would ban inducement advertisements outright and prohibit the term “free bet”. [1]
- Paragraphs 728 to 729 would ban all content marketing by licensed operators on social media. [1]
- Paragraph 749 recommends that affiliates be licensed directly by the Gambling Commission. [1]
- Paragraphs 574 to 577 would ban operator branding on team kits, training kits and venues, with a transition of several years consulted on for clubs outside the Premier League. [1]
Those five items between them remove customer relationship marketing, welcome and reload offers, influencer content and a good part of affiliate traffic, which for most online operators carries more new accounts and repeat play than broadcast has for years. A board reading the package as a sport story will price it wrongly.
The committee also published the measured effects it relied on, and they are specific enough to model with. A randomised field experiment in Australia found that customers who opted out of direct marketing went on to place 23% fewer bets, spend 39% less and report 67% fewer short-term harms. [1] A separate randomised trial found that inducements raised betting spend by more than 10% and made customers less likely to stop betting, and in Spain, restrictions on inducements aimed at new customers were followed by a sustained fall in new account openings and in total amounts staked. [1] Those figures will be quoted at a board sooner or later, so it is better to have applied them to the operator’s own channel mix first.
What should operators do in the next 30 days?
Find out what each acquisition channel is actually worth, market by market, because no restriction scenario can be priced without that figure and most groups do not hold it in a form a board can read.
- Split new accounts and net revenue over the last 12 months by channel: direct marketing, bonus and inducement offers, affiliates, paid social, influencer and content marketing, broadcast, sponsorship, and brand search. Do it per licensed market, since the restrictions arrive market by market.
- Mark every channel against each of the five restrictions above, so the board sees which revenue lines go under which outcome.
- Pull every marketing and sponsorship contract and record its notice period, its change-in-law termination right and the cost of leaving early, because multi-year shirt and venue deals are where the money gets trapped.
- Check which affiliate partners would survive being licensed directly, because an affiliate that cannot hold a licence stops being a channel and becomes an exposure.
- List the markets where a restriction already has a date behind it rather than a proposal, since those are the ones that hit the 2027 budget.
Where does the argument for and against a ban actually conflict?
On displacement, and neither side has settled it. At paragraphs 444 to 452 the committee holds that the evidence against the displacement argument is stronger than the evidence supporting it, and warns that the argument should not be given unjustifiable weight. [1] Bacta told the same committee the opposite, that nobody has properly studied what advertising restrictions do to the visibility of unlicensed operators. [1] Grainne Hurst, chief executive of the Betting and Gaming Council, called the report deeply misguided on 24 September 2026, pointing at Italy and at the Netherlands, where roughly half of gambling spend now sits outside the licensed market. [2]
Italy is the awkward precedent for both arguments at once. The committee itself notes that Italian operators worked around the ban using what it calls alibi brands, LeoVegas.News among them, and that three Serie A clubs still carried gambling sponsors. [1] The Nexus Report published on 15 May 2026 then put illegal online play in Italy at about EUR 20bn, with more than 4.5 million Italians using unlicensed platforms across more than 13 million sessions in the first quarter of 2026, nearly half of them under 35. [3] The acquisition channels that research names are Instagram, Telegram, WhatsApp and YouTube, which are the same places the committee proposes to remove licensed content marketing from, and nobody on either side has produced evidence about what happens to consumer attention in between. [3]
What do Italy, the Netherlands, Belgium, Spain and Brazil show?
That advertising restrictions have reduced licensed revenue more reliably than they have reduced gambling demand, and that they rarely stop where they were first drawn.
| Market | Instrument and date | What it covers | What followed |
| Italy | Article 9, Law Decree 87/2018, in force since 2018 | Near-total ban on advertising and sponsorship for cash-prize gambling | Workarounds through news-style brand domains such as LeoVegas.News, three Serie A clubs still carrying gambling sponsors, and around EUR 20bn of illegal online play by 2026 |
| Netherlands | Besluit ongerichte reclame kansspelen op afstand from 1 July 2023, sponsorship from 1 January 2024 and 1 July 2025 | Untargeted advertising first, then programme and sports sponsorship, with a near-total online ban and a bonus ban proposed in 2026 | Licensed online gross gaming revenue down 18% across 2025, and 47% of gambling spend with illegal operators while 91% of players stayed with licensed sites |
| Belgium | Royal Decree of 27 February 2023, in force 1 July 2023 | Near-total advertising ban with sponsorship withdrawn in phases | Industry-commissioned surveys recorded a 6% rise in online players using an illegal site, and one count put 2,214 illegal sites in the market in 2023 |
| Spain | Royal Decree 958/2020, partly annulled on 10 April 2024 | New-customer promotions, public figures in advertising, social media and video-sharing platforms | The Supreme Court struck those provisions down for lack of legal cover, so operators had to rebuild channels they had already closed |
| Brazil | Interministerial Ordinance 73/2026 from 10 July 2026 and SPA Ordinance 1,964/2026 from 17 July 2026 | Warnings covering at least 10% of every advertisement, with anything aimed at minors treated as abusive | Liability extended to creative agencies, influencers and affiliates alongside the operator, with enforcement precedent still forming |
| Bulgaria | Gambling Act amendments announced on 25 September 2026 | Billboards, posters, public displays, illuminated signs and casino window displays | Follows 2024 restrictions on television, radio and online that pushed promotion outdoors; shirt and sports hall branding kept |
A restriction does not stay where it is drawn
Bulgaria restricted gambling advertising on television, radio and online in 2024, the spend moved outdoors, and on 25 September 2026 the prime minister announced amendments to the Gambling Act banning billboards, posters, public displays, illuminated signs and casino window displays. [6] Model the second round as well as the first, because a budget that simply moves to the next available channel invites the next restriction.
A ban can be reversed, so plan in both directions
Spain’s Royal Decree 958/2020 was partly struck down on 10 April 2024, when the Supreme Court annulled the provisions covering new-customer promotions, public figures in advertising, and advertising through social media, on the ground that they lacked legal cover. [5] That judgment is final, so Spanish operators ended up rebuilding a marketing capability they had already dismantled, with the staff and the agency relationships gone.
The liability perimeter is widening past the operator
Brazil’s Interministerial Ordinance 73/2026, effective 10 July 2026, and SPA Ordinance 1,964/2026, effective 17 July 2026, require warnings covering at least 10% of each advertisement and hold platforms, creative agencies, influencers and affiliates accountable alongside the operator. [7] Read next to the committee’s recommendation that affiliates be licensed directly, the direction is the same in two very different markets.
The money leaves before the players do
The Kansspelautoriteit’s monitoring report of 16 April 2026 is the clearest consumer behaviour evidence available anywhere. Dutch licensed online gross gaming revenue was EUR 602m in the second half of 2025 against EUR 600m in the first half, an 18% fall across the year, and the regulator put 47% of gambling spend with illegal operators while about 91% of players used only licensed sites. [4] So the licensed player base largely held while the higher-spending money moved, which is a different problem from losing customers and needs a different answer.
What are the strategic actions for the next 12 months?
Build one advertising exposure sheet per licensed market and keep it current, then run the rest of the plan off it. Each sheet should hold every acquisition and retention channel with the share of new accounts and of net revenue it produced over the last 12 months; one row per restriction scenario marking whether that channel survives it; the notice period, change-in-law termination right and early exit cost of every contract tied to that channel; the date each restriction in that market takes effect or is credibly expected; and a modelled revenue effect built from a published measured figure rather than an internal estimate, with the figure used and its source named on the sheet, so the board argues with the assumption instead of the conclusion.
- Shift the acquisition mix toward channels a restriction cannot reach, which in practice means brand and organic search, retail where the group has it, and retention mechanics that do not depend on an offer being advertised.
- Move affiliate relationships onto contracts that survive licensing, with beneficial ownership recorded, a warranty that the partner will hold any licence a regulator introduces, and a termination right if the partner is refused one.
- Re-price sponsorship on exit terms rather than reach, and stop signing anything running past the earliest credible restriction date in that market without a change-in-law break clause.
- Separate the retention plan from the acquisition plan in the budget, because a direct marketing ban hits existing customers rather than new ones.
- Keep a dated paper on displacement holding the operator’s own channelisation data, by player and by spend, per market, because the committee has said it will not accept the displacement argument without evidence.
Boardroom Questions
- What share of our new accounts and net revenue in each market came from direct marketing, inducements, affiliates and social content last year, and who owns that number?
- Under the narrower package rather than a full ban, which of our revenue lines disappear, and what is the modelled figure?
- Which marketing and sponsorship contracts run past the earliest credible restriction date in their market, and what does leaving early cost us?
- Which of our affiliate partners would pass direct licensing, and what happens to the traffic from the ones that would not?
- If welcome and reload offers were prohibited tomorrow, what replaces them, and has anyone costed it?
- What is our own channelisation evidence, by player and by spend, and would we be content to put it in front of a parliamentary committee?
- Which markets on our licence list already have a dated restriction rather than a proposal, and are those dates in the 2027 budget?
- If a restriction were reversed in court, as it was in Spain, how quickly could we rebuild the channels and the team we had closed?
Sources
[1] House of Lords Liaison Committee, Gambling Harm: Time for Action: Follow-up report, HL Paper 52, published 17 September 2026. https://publications.parliament.uk/pa/ld5902/ldselect/ldliaison/52/5202.htm
[2] Betting and Gaming Council, comments by chief executive Grainne Hurst on the Liaison Committee report, 24 September 2026, as reported by Yogonet. https://www.yogonet.com/international/news/2026/09/24/126546-bgc-warns-uk-gambling-ad-ban-could-weaken-consumer-protection
[3] Data Room Nexus Observatory, Nexus Report: Osservatorio Gioco Online Illegale, published 15 May 2026, as reported by Yogonet. https://www.yogonet.com/international/news/2026/05/15/120637-italys-illegal-gambling-market-grows-despite-advertising-crackdown
[4] Kansspelautoriteit, Monitoringsrapportage online kansspelen voorjaar 2026, published 16 April 2026. https://kansspelautoriteit.nl/monitoringsrapportage-voorjaar-2026-marktontwikkeling-blijft-gelijk
[5] Spanish Supreme Court judgment on Royal Decree 958/2020, published 10 April 2024, with analysis by GamingTechLaw. https://www.gamingtechlaw.com/2024/04/spanish-gambling-advertising-ban-invalidated-supreme-court/
[6] Bulgarian Gambling Act amendments announced 25 September 2026, as reported by Yogonet. https://www.yogonet.com/international/news/2026/09/25/126562-bulgaria-moves-to-ban-outdoor-gambling-advertising-raise-online-betting-fees
[7] Brazil, Interministerial Ordinance 73/2026 effective 10 July 2026 and SPA Ordinance 1,964/2026 effective 17 July 2026. https://brightsideofnews.com/gambling/brazil-betting-ads-liability-2026/
[8] Netherlands, Besluit ongerichte reclame kansspelen op afstand and the 2026 advertising and bonus package, NL Times, 12 June 2026. https://nltimes.nl/2026/06/12/netherlands-moves-near-total-ban-online-gambling-ads-amid-loophole-crackdown
[9] Belgium, Royal Decree of 27 February 2023 and post-decree channelisation evidence, iGaming Business, 8 April 2024. https://igamingbusiness.com/legal-compliance/regulation/belgium-report-warns-impact-over-regulation-channelisation/
[10] AGCOM Resolution no. 132/19/CONS implementing Article 9 of Law Decree no. 87/2018 (Decreto Dignita), analysis by Portolano Cavallo. https://portolano.it/en/newsletter/portolano-cavallo-inform-digital-ip/italian-communications-authority-issues-new-guidelines-softening-the-restrictions-on-gambling-and-betting-advertisements-provided-by-the-decreto-dignita