A responsible gambling campaign in Italy can now carry the operator’s own logo, and AGCOM has set out how small that logo must be, where it may sit, and how long it may stay there.1
Brazil, the Netherlands and the United Kingdom each answer the same question differently, so an operator licensed in more than one of them can no longer run one creative through a single approval. The questions below must be settled before the next responsible gambling campaign is commissioned.
Key Takeaways
- A responsible gambling campaign in Italy may now carry a licensed operator’s own trademark. AGCOM, Italy’s communications regulator, adopted Delibera 200/26/CONS on 29 July 2026 and published it on 10 August 2026, setting the conditions within an advertising ban that has applied since the Dignity Decree took effect in 2018.1, 3
- Italian concessionaires already have to spend 0.2% of net revenue a year on responsible gambling communication, capped at €1 million, under Article 15(2) of Legislative Decree 41/2024, so the money is compulsory and these rules decide what it buys.2
- Brazil hands the wording to the state, requiring one of three Ministry of Finance warnings at a minimum of 10% of the advertisement; the Netherlands is drafting a ban with two carve-outs, and neither is a prevention message; and the United Kingdom pays for prevention through a statutory levy the industry has no say over.4, 6, 7
- The €1 million cap is reached at €500 million of net revenue, so Italy’s largest operators spend proportionally less on prevention communication than their smaller competitors do.2
What does Italy now allow in a responsible gambling campaign?
Italy allows an operator’s logo on a responsible gambling campaign where it identifies who is speaking and does nothing else. The delibera adds to the 2019 guidelines in Delibera 132/19/CONS, and most of its length goes on turning a permission that has existed since 2018 into something a compliance team can test. Responsible gaming logos were carved out of the Dignity Decree ban from the beginning, but for eight years nobody set out where that carve-out stopped.3
The marginality test has four parts, and a responsible gambling campaign fails if it misses any one of them:
- Contained dimensions, measured against the size of the warning text rather than against the frame.
- Placement in a corner or a lateral area, never the centre.
- No animation or progressive enlargement.
- Limited exposure time in audiovisual formats.
The permission falls away altogether where the trademark is also the name of a gaming product, which catches a fair number of brands.1
The content exclusions are blunter. Out are winnings, jackpots, bonuses, odds and any other economic advantage; any call to action, however phrased; slot sounds, reels, cards, dice and gaming interfaces; and any commercial slogan or emphasis on the brand itself. Influencers are excluded in every context, and celebrity testimonials are allowed only where the message is genuinely about moderation and risk, not where that person already fronts the operator’s commercial brand elsewhere.1
Links carry four conditions that all have to hold at once: no promotional content or product information on the destination page, no profiling of the people who arrive, data minimised and neither reused for marketing nor passed to third parties, and the protection area technically separated from the gaming site in a way AGCOM can verify.1
The evidence goes to the Department for Information and Publishing and to ADM every year: what ran, what it cost, how far it travelled, and how comprehension, recall and behaviour change were measured. Most marketing functions will have the first three and not the fourth.1
Why do responsible gambling campaign rules differ by market?
Because responsible gambling campaigns are regulated differently in each market, and three other substantial markets are deciding the same question right now, these campaigns must be approved market by market instead of once for the group.
| Market | What the rule does | Whose name is on the prevention message | Date |
| Italy | Permits a marginal operator logo on prevention campaigns inside a general advertising ban | The operator’s in a corner | Delibera 200/26/CONS, adopted 29 July 2026 |
| Brazil | Requires one of three fixed Ministry of Finance warnings at a minimum of 10% of the advertisement, with duties spread across operators, media, platforms and influencers | The state’s words, carried by the operator | Warnings required from 17 July 2026; CONAR Annex X update approved 27 August 2026 |
| Netherlands | Cabinet plans a full ban on online gambling advertising and bonuses, with carve-outs only for the operator’s own website and search results for explicit gambling queries. | Nobody’s outside those two places. | Announced 12 June 2026, bill in drafting |
| United Kingdom | Statutory levy of 0.1% to 1.1% of leviable revenue, with 30% of it directed to prevention and no industry say over how it is spent | Not the operator’s at all | Gambling Levy Regulations 2025, in force 6 April 2025 |
One creative question gets three answers across Italy, Brazil and the Netherlands. Italy wants the logo present and marginal, Brazil wants a government sentence taking up a tenth of the frame, and the Netherlands, once the bill passes, may leave nowhere to run it outside the operator’s own website.6
Is the message lawful in every market where it runs?
A responsible gambling campaign is not automatically lawful, because Italy, Brazil, and the Netherlands each treat prevention messaging under a different rule from the one governing ordinary advertising.
1. Which of our markets treat a prevention message as advertising, and which treat it as its own category with its own conditions?
2. Where we rely on permission, is it written down in a rule, or are we relying on the fact that nobody has objected yet?
3. Who signs off that a specific creative is prevention rather than promotion, and does that person sit in marketing or in compliance?
4. Where a market bans advertising and says nothing at all about prevention messaging, what is our default position, and who set it?
Whose brand is on it, and how far does it go?
The brand goes further into a responsible gambling campaign than most creative teams assume, since the Italian test measures the logo against the size of the warning text, not against the frame.
5. Is our trademark also the name of a gaming product, which would take us outside the Italian permission altogether?
6. What is our own written test for a marginal logo, covering size, position, movement and time on screen?
7. Are we using a testimonial, and is that person already carrying our commercial brand in another market?
8. Watched with the sound off by someone who does not know us, does the campaign read as prevention or as brand advertising?
Where does the click go?
The click has to go to a page that stays clean of anything promotional. AGCOM also wants to be able to check the separation between that page and the gaming site.
9. Does the destination page carry any promotional content, odds, bonuses or product information?
10. Are we profiling the people who arrive there, or feeding that traffic into a marketing audience?
11. Is the protection area technically separated from the gaming site, and could we demonstrate that separation on request?
12. What data do we keep from that traffic, for how long, and who else receives it?
What does the money buy, and who checks?
In Italy the spend is fixed by statute, so the only thing left to decide is whether the campaign works and whether anybody measured it.
13. What is 0.2% of our net revenue in each market that imposes a spend obligation, and does the cap mean we spend proportionally less than smaller competitors?
14. What did we test before the campaign ran, and what have we measured since: recall, comprehension, or whether anyone actually set a limit or used a self-exclusion tool afterwards?
15. If awareness rose and tool usage did not move, what changes in next year’s responsible gambling campaign?
16. Who on the board sees that measurement, and at what point in the year?
What to do before your next responsible gambling campaign
Route every responsible gambling campaign market by market, then build the evidence file before the annual return asks for it.
1. List every market where the business runs a responsible gambling campaign or advertises at all, and mark each one as banned, permitted with conditions, or mandated wording. That list becomes the routing table every future campaign goes through.
2. Pull the last twelve months of responsible gambling campaigns and test each one against the marginality and content rules above, since AGCOM takes the view that relief for campaigns already contracted should be limited. The Responsible Gambling Marketing Review Framework covers the pre-campaign approval and post-campaign monitoring this step needs, and the per-market routing in step one is the piece to build around it.
3. Assemble the evidence file in one place: the 0.2% calculation, the pre-testing results, the segmentation criteria, the media plan, the creative rationale, and the post-campaign measurement of comprehension, recall and behaviour.
A responsible gambling campaign that fails these tests counts as gambling advertising, which carries an administrative fine of at least €50,000 for each breach. Italy published the rules on 10 August 2026, so anything running now is running under them.3
Sources
1. AGCOM, Delibera n. 200/26/CONS, ‘Atto integrativo delle linee guida per le campagne di comunicazione contro i disturbi da gioco d’azzardo’, adopted 29 July 2026, published 10 August 2026, https://www.agcom.it/provvedimenti/delibera-200-26-cons
2. Decreto Legislativo 25 marzo 2024, n. 41, Article 15(2), responsible gambling communication spend for remote gaming concessionaires, https://www.gazzettaufficiale.it/eli/id/2024/04/03/24G00057/sg
3. Decreto-Legge 12 luglio 2018, n. 87 (Decreto Dignita), Article 9, converted by Legge 9 agosto 2018, n. 96, https://www.gazzettaufficiale.it/eli/id/2018/07/13/18G00112/sg
4. Ministerio da Fazenda, Secretaria de Premios e Apostas, Ordinance SPA/MF No. 1.964/2026 of 3 July 2026 and Interministerial Ordinance MF/SECOM/MJSP No. 73/2026 of 10 July 2026, warnings required from 17 July 2026, https://www.gov.br/fazenda/pt-br/composicao/orgaos/secretaria-de-premios-e-apostas/apostas-de-quota-fixa/legislacao
5. CONAR, ‘Atualizacao do Anexo X amplia restricoes a publicidade de apostas’, approved 27 August 2026, in force 30 days after publication, https://www.conar.org.br/noticias/atualizacao-do-anexo-x-amplia-restricoes-a-publicidade-de-apostas
6. Rijksoverheid, ‘Kabinet scherpt beleid online kansspelen flink aan’, 12 June 2026, https://www.rijksoverheid.nl/actueel/nieuws/2026/06/12/kabinet-scherpt-beleid-online-kansspelen-flink-aan
7. The Gambling Levy Regulations 2025 (SI 2025/213), made 25 February 2025, in force 6 April 2025, https://www.legislation.gov.uk/uksi/2025/213/made
8. Department for Culture, Media and Sport, ‘Statutory levy and online slot stake limits to be introduced to tackle gambling harm’, https://www.gov.uk/government/news/statutory-levy-and-online-slot-stake-limits-to-be-introduced-to-tackle-gambling-harm