Regulating influencer marketing in gaming and gambling

Introduction

The idea of vacuous, self-absorbed individuals commanding attention and sizeable sums of money may grind our gears, but influencer marketing is here to stay, and it affects the gaming and gambling industry. This article explores how influencer marketing in gaming and gambling can be regulated in ways which are likely to achieve their objective.

A 2024 study into social media marketing by four leading U.S. gambling brands – BetMGM, FanDuel Sportsbook, ESPN Bet, and DraftKings Sportsbook – found that over 81 percent of the ads sampled were organic, as opposed to paid. Of these, half were considered content marketing, that is marketing that focuses on engaging, shareable content, without explicitly advertising a brand product or service.[1] This finding is consistent with others which indicate the growing use of influencer marketing by gaming and gambling operators.

Influencer marketing is also projected to be one of the fastest growing aspects of affiliate marketing with more than half (59%) planning to dedicate a quarter or more of their affiliate budget to influencer marketing partnerships in the next year. This equates to a 14 percentage point net change according to a 2025 report from impact.com.[2]

Influencer marketing is not new. A report entitled The State of Influencer Marketing 2020: Benchmark Report was quoting an industry worth US$9.7 billion five years ago.[3] Many in the industry, including regulators, have taken a while to realise that this kind of advertising is not just confined to makeup brands and restaurants, but this is set to change if it hasn’t already.

In recent months, there have been a string of announcements concerning the use, the regulation and enforcement of rules against influencer marketing in gaming and gambling. France was one of the quickest out of the blocks with legislation, passed in 2023, threatening a two-year prison sentence and €300K fine for the creation of promotional content for online gambling. That law prohibits influencers from creating paid content promoting cosmetic surgery, online sports betting sites, professional training courses, and online gambling. The legislation also requires influencers to label all paid content and disclose any filters used on promotional photos.

Germany, and, most recently, the Netherlands have followed similar approaches and there are signs the UK is preparing to do the same.

Most recently, in October 2025, the European Gaming and Betting Association (EGBA) announced a commitment to establishing new guidelines for ethical influencer marketing in the European gambling sector.[4] Just a few days later, GambleAware, the soon to be disbanded, UK charity, called for a ban on influencer marketing in gambling claiming “current regulations for marketing gambling online are not fit for purpose”.[5]

These reactions are a sure sign that awareness of influencer marketing is growing, but are the regulatory steps being taken or considered likely to achieve the desired outcome? More likely, some argue, influencer marketing will be another area where the regulated market is placed at a disadvantage to the unregulated one and consumers will be the losers.

The influencers and the influenced

It is important first to distinguish between influencers and celebrities. In his 2023 article for IMGL, Luís Carvalho argued: “The[celebrity] faces of the big luxury brands may be rewarded through their social media activities, but this is different from those who have achieved influence through their social media content and channels. They are followed for the value and authority of their content rather than for who they are. Streamers are “humans like us” fostering a sense of proximity with the viewers and making their influence much stronger. They are the beneficiaries of the democratization of content generation and provision. This contrasts with celebrities whose “god-like” appearances are deployed by brands.”[6]

It is important to understand that influencers in the gambling space, as with many other niches, are those who genuinely love playing the games they’re promoting. It is this authenticity that makes them relatable and gives them the influence they have. As well as being avid players, these individuals are also good at finding ways to maximise rewards, either in terms of entertainment or monetary value. They are also technically sophisticated. We will explore why these factors are important later on.

Influencers’ original ambitions may not have been financial: many will have started playing the games they love, sharing content of themselves doing so and building up a following of likeminded people who see value in the content they create. Once attracted, their audience is carefully nurtured and fed with content that generates the most interest. At this point influencers may become influencer marketers and start to monetise the audience and influence they have.

Monetisation may come from advertising and affiliate revenue, but for the most successful, there are significant rewards to be gained from sponsorship deals. Whilst no one is calling influencers victims, they are self-employed entrepreneurs and will only continue to generate income whilst their channel is successful. They are thus highly motivated to keep doing what they’re doing and will often demonstrate considerable ingenuity if attempted barriers are put in their way.

In the gambling sector, influencers can be categorised into various niches, such as sports betting influencers who provide tips and insights, casino influencers who review games and platforms, and poker influencers who share strategies and tournament updates. Each type of influencer caters to a specific audience within the broader gambling community.

The gaming space often uses gameplay elements which are considered gambling in many jurisdictions, and here influencers play an arguably greater role. A 2021 YouGov survey found that two-thirds of US teens follow influencers (against 29 percent of adults) with gaming content followed by 36 percent of individuals, second only to music content at 39 percent.[7]

This is a useful segue to examining who the followers of gambling influencer content are. As the YouGov data shows, the gaming demographic skews strongly towards teenagers and young adults. This changes when it comes to streaming of gambling content where 18-30-year-olds make up around 60 percent of the global audience on platforms like Kick.[8] It may seem obvious why they’re tuning in, but it is worth pausing briefly to understand what audiences get out of it.

Researcher, Jamie Torrance of Swansea University has carried out one of the few empirical studies into the behavior of followers.[9] Participants in the study describe following their favourite streamers of gaming content, people who they bond with. Then, when these streamers migrate to producing gambling content, they follow and this is often their pathway into gambling. They speak of intense gambling sessions where eye-watering sums are won and lost by streamers. Their connection to the streamers means followers of their content are emotionally invested in their success or failures.

Casino-style features embedded into the streaming platform were also described in detail. Viewers earn “channel points” for watching streams, creating progression systems that mirror slot machine reward schedules. These points can be wagered on stream outcomes – essentially gambling on gambling – then redeemed for custom rewards, such as a shout-out from the streamer.

One surprising revelation is that participants say they watch streams as a safe alternative to gambling themselves. Instead of satisfying the urge, however, they report intensified cravings and increased real-money gambling as a result of viewership.

The power of streamers to influence behavior is even greater among a younger audience. Combine this with poor age verification on the streaming platforms and there is great potential for harm among teenagers.

Regulating influencer marketing in the regulated gambling market

Influencer marketing is not intrinsically bad, neither are the challenges of influencer marketing exclusive to gambling. They are the same challenges for pharmaceuticals, for alcohol, for all sorts of areas where influence can be either positive or negative. The task for legislators and regulators is to create the market conditions to incentivize them to do it responsibly. That also goes for the enablers of their businesses, the platforms they use, the payment systems they rely on and those who pay them for their services.

There is broad consensus that influencer marketing in gambling requires regulation, but before regulators start dreaming up new laws in this area, it’s worth considering what already exists. In many jurisdictions, there are already laws against promoting illegal gambling. Too heavy handed an approach risks turning influencer marketing into another marketing tool where the regulated market faces tight restrictions when black market operators face none.

The prevalence report referenced above revealed not only how much influencer marketing was being used by operators but also a worrying lack of compliance with existing marketing rules. The report authored in 2024 by Dr Raffaello Rossi and his colleagues at the University of Bristol found that whilst all the paid-for ads they studied adhered to AGA regulations stipulating the inclusion of safer gaming messages and help hotlines, only 25 percent of organic ads adhere to the codes.[10] This meant that, over the period of the study which was only a single week, there were over 1000 pieces of content marketing from major casino and sports betting brands which contravened advertising codes.

Faced with a similar wave of influencer marketing promoting legal gambling platforms in Norway, the regulator successfully disrupted it using a tried and tested approach. Speaking at the IMGL conference in Lisbon, Trude Høgseth Felde, Senior Advisor to the Norwegian Gaming Authority related her organization’s dealings with Kapow.com, an influencer collective.

“This was a group of influencers that collaborated to form a super affiliate site, kapow.com. They each had individual followers. They recruited new followers, and they were all aiming to reach our youngest. They went partying, they went on exotic travels, expensive cars, gambling. There were celebrities and sports stars creating big stories and of course, this plays with young people’s fear of not being part of the community, the fear of missing out.

Having identified the activities of the group, we sent out a notice and we also threatened action against their clients. Surprisingly, two hours after our notice went out, the website closed down, and we received emails from each and every one of the individual influencers that they would delete all the content and stop their activities. In some cases they had no idea that what they were doing was illegal and just informing them was enough to persuade them to stop.”

Another speaker on the same panel agreed. “Influencer marketing in gambling needs rules, but the same applies in pharmaceutical products, in high sugar products and many other areas. There are already laws in place covering promotion of these things: what we’re lacking is enforcement. So, before we talk about further restrictions on the regulated market, we need to enforce the current law. In my country of Portugal, nobody has been arrested for promoting illegal gambling even though it’s crime. Influencers have an important role in educating the consumer.

“The mission of regulators in Europe is to provide a regulated framework for operators, to protect the consumer and to generate tax revenue for the state. In many cases we have the legal framework we need to achieve that so we should start with enforcement rather than greater regulation.”

For some, the scale of the challenge is overwhelming. There are so many pieces of content being created and circulated that monitoring it and mounting an effective response is beyond the scope of advertising standards bodies established in different times. Influencer marketing, alongside other new marketing methods, requires a modern response to regulation. Programmed well, AI can be the regulator’s friend here. It can identify content which breaches advertising codes and even send automatic cease and desist notices leaving the regulator to focus only on persistent offenders.

Under many legal regimes, operators who commission marketing are responsible for its content. The European Gaming and Betting Association’s (EGBA) recent launch of an industry-wide pledge “establishes enhanced standards for transparency, the protection of minors, and independent monitoring for influencer marketing in Europe’s gambling sector”, according to the organization.[11]

Regulating influencer marketing in the unregulated market

As the Norwegian experience above shows, when influencers were informed their actions were illegal, they didn’t stop influencing, they just moderated their behaviour. In many other examples, however, this has not been the outcome and the influencers moved to promoting black market operators. It’s easy to categorise such behaviour as the actions of individuals with criminal tendencies, but the reality is more complex. In most cases, they are simply applying business logic to their decision making.

A report from Deal Me Out revealed the clear-eyed logic behind the move to the black market by ten gaming influencers following a change in UK rules.[12] All the content creators were fundamentally opposed to returning to the regulated market whilst restrictions are in place and with almost all content creators playing on the Black Market, their audience is sure to follow. That means it is only a matter of time before migration to the Black Market, in particular Crypto Casinos, is the new normal for a young audience.

The rationale given by the influencers is as follows:

• Creating content on Black Market is less time consuming due to bonus buys, turbo spins etc.
• There is increased affiliate financial return
• They see hugely increased VIP scheme returns, rake back, and enticements compared to the regulated market
• There is lower viewership on lower stake videos: why spend time creating content with limited appeal when creators on the black market can utilise unlimited bet limits
• Content creators on the UK licensed market are unable to compete with global players who are working without similar restrictions
• Ability to use bonus buys and turbo spins for personal enjoyment

This last point demonstrates just how important it is to this group that they are allowed to continue to play the games they love in the way they want. Banning games or introducing restrictions on stakes, speed or types of gameplay send an instant message that influencers should fire up the VPN and find a market without the restrictions.

The Deal Me Out report found remarkably similar frustrations among consumers with an overwhelming number concerned that regulation was pushing them into the Black Market. 84 percent of respondents agreed that slot regulation (no turbo spins, no bonus buys, lower limits, slower spins) influenced their decision to migrate to the Black Market and 80 percent of respondents felt deposit limits and affordability checks were the main reason for migration.

This group may not be content creators themselves, but they will almost certainly be influenced by them as they are part of the same community. Having vocal and respected players airing their frustrations plays into the hands of Black Market operators who will often welcome them with open arms.

A 2025 study into the Black Market by the UK Gambling Commission profiled typical Black Market players.[13] The report found that they are generally men, between the age of 18 and 24, who are active gamblers, and who usually rank eight or above on the Problem Gambling Severity Index (PGSI) problem gambling scale. They typically go to the black market to bet on football, for online bingo, or to play online fruit or slot games.

The motivation behind going out of their way to find illegal sites are most often better odds and offers, games unavailable elsewhere, access to alternative payments like crypto, no stake limits, and a low entry barrier – meaning weak ID or financial checks. This suggests a significant prevalence of harmful gambling behavior is likely to be exhibited by this group in an environment where harm prevention is weak.

If regulators are unwilling to reconsider tighter restrictions, then the only options open are to try and enforce regulations on influencers promoting Black Market products or to tackle the Black Market itself. Both of these are challenging. First, it is by no means always clear that influencers are breaking the law. Simply streaming themselves playing a crypto casino game is probably not illegal and proving a commercial connection to an unregulated operator is not easy.

AI tools are emerging in this area which show promise. Lex Hunter is an artificial intelligence platform designed to detect, map, and document the digital ecosystem of igaming, including the involvement of influencers in its promotion. The system can capture the full universe of gambling-related content, even that which remains invisible to conventional search or monitoring methods. Once content is identified, a validation module determines whether the promoted activity is legal or not within that jurisdiction.

In the case of influencers, the system not only detects posts or live streams related to gambling; it also automatically builds relational networks linking those profiles to operators, agents, cash handlers, satellite services, and distribution channels. Lex Hunter monitors active channels, captures and analyzes content from social networks, streaming platforms, and closed communities, and generates structured multimedia evidence whenever direct or covert promotional behavior is detected.

A common complaint is that an overwhelming number of sources of illegal content pop up as fast as others are removed. Here, too, Lex Hunter can help with fully automated tools, requiring no human intervention, specifically designed to dismantle unregulated gambling infrastructures operating within social networks and messaging platforms such as Meta, Telegram, Discord, and WhatsApp. During a recent deployment in Latin America, the system executed over 190,000 actions over three months, demonstrating its ability to work at scale in this space. Using humans for the same task would have taken much longer or required a level of investment beyond the scope of most regulators.

Beyond the influencers themselves, more regulators are trying to disrupt the ecosystem that supports unregulated products. This means working with B2B service providers, payment companies, and digital platforms on which their business model relies. It also means greater collaboration between jurisdictions. As countries like Australia, which have made concerted efforts to tackle offshore operators have shown, the task is one which never ends.

Conclusion

Regulating influencer marketing in gaming and gambling is set to become increasingly important as its use grows as part of the marketing mix. Regulators should take care that their response should not be to reach reflexively for a ban as this is unlikely to be successful in protecting players. Rather, there is a process of education both of brands and influencers are to what is illegal marketing, and at least a possibility that they can be recruited to the cause of consumer protection.

One of the missions of regulation is to maximise market share, retaining as large a part of the gambling market within licensed operators. This requires a nuanced and considered approach to influencer marketing as well as a multi-pronged offensive on the unregulated market.

Influencers are knowledgeable and active players of the games they promote and many consider crypto to be the future. Recent suggestions that regulation be adapted to include crypto casino would certainly keep the regulated market open as an option for these individuals.

Phil Savage is Head of Publications and European Affairs at IMGL

[1] https://www.bristol.ac.uk/media-library/sites/business-school/documents/Bristol_SM_Research_Report.pdf

[2] https://impact.com/research-reports/state-of-affiliate-marketing/

[3] https://influencermarketinghub.com/influencer-marketing-benchmark-report-2020

[4] https://www.egba.eu/news-post/egba-launches-pledge-on-responsible-influencer-marketing/

[5] https://www.gambleaware.org/media/0xrns0z4/online-gambling-marketing-policy-paper.pdf

[6] https://www.imgl.org/publications/imgl-magazine-volume-3-no-1/influencer-marketing-in-gambling-and-gaming/

[7] https://yougov.com/reports/38826-international-gaming-report-2021

[8] https://zipdo.co/kick-statistics/

[9] https://theconversation.com/why-people-are-watching-livestreams-of-influencers-gambling-and-how-it-could-be-fuelling-addiction-266532

[10] https://www.bristol.ac.uk/media-library/sites/business-school/documents/Bristol_SM_Research_Report.pdf

[11] https://www.egba.eu/uploads/2025/10/251020-Responsible-Influencer-Marketing-in-Online-Gambling-1.pdf

[12] https://www.dealmeout.org/_files/ugd/81a066_2eb4a60f592c47e0b233b81e9c1cf9b4.pdf

[13] https://www.gamblingcommission.gov.uk/report/illegal-online-gambling-consumer-awareness-drivers-and-motivations