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Italian responsible gambling advertising is entering a new phase where strict regulatory obligations coexist with a real opportunity for operators to communicate their brand.
Italy’s communications regulator, AGCOM, has published new draft guidelines that aim to define how operators can carry out responsible gambling campaigns without breaching the general prohibition on gambling advertising.
The Legal Framework: A Ban With a Built-In Exception
To understand the significance of these rules, you need to look at the broader legal framework.
Since 2018, Italy has enforced a near-total ban on gambling advertising under the Italian Dignity Decree. The ban covers virtually all forms of promotional communication, both online and offline—even though this has led to the proliferation of news, video, and social media platforms indirectly referring to gambling brands.
A major shift has occurred with the introduction of the new remote licensing regime, which requires operators to run responsible gambling campaigns that explicitly refer to their brand.
This creates a structural tension:
- advertising is prohibited;
- but communication on responsible gambling is required.
To address this, AGCOM has now attempted to define a narrow “safe zone” where such campaigns can exist without breaching the ban.
The Core Obligation: Responsible Gambling Is Not Advertising
The starting point is clear and uncompromising.
AGCOM’s position is that:
responsible gambling communication is not advertising—provided that it contains no promotional element.
To remain compliant, operators must ensure that their campaigns:
- avoid any direct or indirect incentive to gamble;
- exclude commercial or branding objectives;
- focus exclusively on public health and user protection.
The Communication Rules: A Highly Restricted Perimeter
The Italian responsible gambling advertising framework imposes detailed and stringent limitations.
Operators must avoid:
- any call-to-action language;
- references to bonuses, odds, jackpots, or winnings;
- visual elements linked to the gaming experience (apps, interfaces, betting screens);
- emotional or aspirational messaging.
Testimonials are also heavily restricted, particularly where they could appeal to vulnerable audiences such as minors or the elderly.
Also, the guidelines introduce a strict “no-link” principle:
- no links to gambling platforms;
- no links to websites connected to the operator, even indirectly.
In addition, AGCOM discourages short formats such as banners or short videos, as they are considered insufficient to convey meaningful responsible gambling messages.
Branding is also significantly limited:
- logos must serve only as a “signature” of the initiative;
- they must appear in a secondary, non-prominent position;
- their size and visibility must be limited.
The Financial Obligation: A Mandatory Investment
The framework is reinforced by a binding financial requirement under the new licensing regime.
Licensed operators are required to allocate on an annual basis an amount equal to 0.2% of their net revenues to responsible gambling campaigns, up to a maximum of €1 million.
This obligation is not optional—it is a condition for holding a license.
As a result, operators face a dual constraint:
- they must invest a minimum amount;
- they must comply with communication rules.
Where the Opportunity Lies
Despite these constraints, there is a dimension that should not be overlooked.
In a market where traditional advertising is almost entirely prohibited, Italian responsible gambling advertising becomes one of the very few legally viable channels to communicate with the public.
Two elements are particularly relevant:
- the requirement that campaigns refer to the operator’s brand;
- the possibility—within strict limits—to increase public awareness of that brand.
What is formally a compliance obligation can, in practice, become a strategic communication opportunity, provided that it is carefully designed.
Operators will need to:
- develop campaigns that are fully compliant yet still impactful;
- rethink how to convey brand identity without promotional language;
- integrate legal and marketing expertise in campaign design.
Compliance Is Now a Strategic Function
The new Italian responsible gambling advertising framework is not just another regulatory requirement.
It fundamentally changes how operators approach communication.
It requires:
- a redesign of communication strategies;
- close alignment between marketing and legal teams;
- robust internal controls to prevent breaches of the advertising ban.
Because in a market where advertising is largely prohibited, every compliant communication opportunity becomes strategically valuable.
What Comes Next
The guidelines are currently subject to a 30-day public consultation. While no major changes are expected, the debate is likely to continue.
Looking ahead, a broader reform of gambling advertising rules cannot be excluded—particularly in light of the financial pressures affecting sectors such as professional football, which have historically relied on gambling sponsorship revenues.
On a similar topic, you can read the article “Italian Court Upholds Sanction for Gambling Advertising Ban’s Violation Through Affiliate Agreements“. Also, you can read about the different gambling regimes in almost 50 jurisdictions in the DLA Piper Gambling Laws of the World guide.