Social media and streaming are now core acquisition channels for online sportsbook and casino brands, as well as for studios and affiliates. They provide unrivalled reach and targeting capabilities, allowing brands to engage new audiences in the places where their attention can be found.

But where there are opportunities, there are also challenges, and social media, as well as the streamers, influencers and content creators who play in the space, can cause headaches for operators, studios and affiliates.

Why? Because social audiences often skew younger, which raises concerns about protecting underage and vulnerable players, and with streamers and influencers, especially those from outside the industry, not always understanding the importance of responsible gambling.

This RoundTable explores whether there is a need for greater regulation of social media advertising and what operators, studios, affiliates and content creators can do to ensure they are being responsible in how they are leveraging the opportunities presented by social media.

Lizzie Thomas Head of Social Media/GameOn
Michela Pace – Marketing Manager at Swintt
Fraser Linkleter, Chief Executive at Slots Temple

How can the gambling industry ensure streamers/influencers/content creators are acting in the best interests of players?

LT: “Streamers, influencers and content creators should have a good understanding of how to engage with audiences responsibly. The platforms used to share their content already have requirements in place for those working in the gambling space, while the gambling brands they work with also have guidelines for how affiliates – which streamers and influencers essentially are – should behave when promoting their brands to their followers. These requirements and guidelines are a solid foundation but can be strengthened through knowledge sharing, education and training, with operators taking most of the responsibility for this as they have the deepest understanding of responsible gambling and how to engage players effectively but safely.”

MP: “When you appoint a streamer to promote your product they effectively become an extension of your brand, so I think it’s very important for companies to really think about the type of message they want to convey and only work with individuals who truly align with it. At Swintt we consider our games to be primarily a form of entertainment, so of course we always try to encourage players to enjoy them in a responsible way. This means that the streamers we work with must also approach our content from this perspective and we ensure that they only ever work with real money so they can give as accurate a depiction as possible of how players can wager responsibly.”

FL: “This is an extremely difficult task but it’s crucial for protecting our players. There need to be clear guidelines and policies to eliminate any grey areas. Everyone needs to know exactly what they can and can’t do. Eliminate all subjectivity. Be super-prescriptive.

“There needs to be a robust internal process to monitor influencer content. You need to be hypervigilant, ensuring you’re always aware of the content you’re putting out there because it’s your responsibility.

“Content creators are not always well-versed in gambling regulation, but they need to be, so it’s vital that they receive proper training rather than simply being given free reign. They need to understand the potential consequences of noncompliance.”

Where is the line between prohibition and regulation with social media advertising?

LT: “It’s always best to regulate an activity rather than prohibit it. The challenge comes in ensuring that advertisers are legitimate and are marketing responsibly via social media networks, streaming platforms, etc. Account approval is effective at doing this, with operators required to provide proof of licences before they are allowed to advertise with the likes of Google and Meta, but it can be harder for content creators, especially in markets where they are not required to be licenced. Most platforms do undertake account verification and approval, with influencers and content creators required to submit supporting evidence and documents including legal letters in some instances. For me, this helps to ensure responsible advertising without the need for prohibition but it is an area where improvements can be made – there are still plenty of fake accounts pushing unlicensed brands slipping through the net.”

MP: “I think this is a tricky balance to strike as on the one hand you want to make sure that social media advertising is regulated and only targets the appropriate audience, but on the other imposing blanket bans or overly prohibitive restrictions denies you the opportunity to educate players on how they can gamble online responsibly. As I mentioned in my previous answer, we take an entertainment-first approach to promoting our content, when we advertise games on social media, we always do so with the appropriate RG and 18+ messaging attached, as this way we can regulate how we come across to customers.”

FL: “Prohibition is unconditional and absolute. Prohibition states there must be age restrictions on channels, that the age of an influencer or celebrity endorsing a gambling product should not be, or seem to be, under 25, that they should not be shown drinking alcohol, and so on.

“These are rules that are set in stone and breaking them can have a significant impact on player harm, which is why there are penalties for doing so.

“Regulation has to be for the elements which require a level of interpretation – ensuring ads are honest, truthful, decent, etc. Regulation provides a framework of guidance and standards for us to work within. Regulation facilitates controled advertising.”

What are your thoughts on new technologies such as AI and facial recognition playing a part in responsible gambling protocols on social media?

LT: “Social media is a platform for engaging with gambling-related content, not actually gambling. The longstanding challenge is ensuring that content is not delivered to underage players or the most vulnerable, and that ultimately comes down to the platform’s ability to segment audiences and block content for those who should not receive it. AI will undoubtedly be able to help with this, but I’m not sure how facial recognition will help other than at a device level and with being able to confirm who is using the device at a given moment in time. That said, social media platforms are cutting-edge and innovative, so if there’s a way for facial recognition to improve responsible gambling, I’m sure they will figure out how.”

MP: “At Swintt, we always try to keep it real as a company – so even though we see AI as an incredibly useful tool for operators and developers, we think a great deal of human input is still necessary if it’s to be used effectively. Of course, one area where technologies like AI and facial recognition can potentially have a major impact from a responsible gambling standpoint is KYC and age verification, so if they can be incorporated in a way that safely and accurately streamlines this process, then we’re more than happy to use them. However, in terms of promoting a consistent responsible gambling message, we prefer using the human touch to engage with our customers.”

FL: “AI and facial recognition are increasingly used by gambling operators to identify potential players at risk of gambling related harm and also to validate identity, and therefore age.

“Perhaps facial recognition could be used by social media giants to guess a person’s age by analyzing the geometry and features of their face to ensure users are seeing age-appropriate advertising. But that would be highly intrusive and would raise a lot of questions about privacy, which could lead to a backlash against the platform.

“I think AI in general has an important role to play in the industry when it comes to age-gating its promotions and services more effectively, but it must be implemented thoughtfully and with the consideration that social media users may be sensitive about data being collected and analyzed.”

Should streamers be held to the same RG standards as operators and developers?

LT: “All stakeholders should be held to the same standards when it comes to responsible gambling. This is an industry-wide effort to protect players, and all stakeholders must play their part. The onus often sits with the operator as it’s their licence that is ultimately on the line, and that’s why they set such stringent guidelines for their affiliates – including streamers, influencers and content creators – to adhere to. But those content creators must genuinely buy into the purpose of responsible gambling and why it must take priority and guide their approach to the content they produce. For me, I would like to see operators do more to educate their marketing partners so that the responsibility of responsible gambling is more equally shared.”

MP: “Absolutely. At the end of the day, streamers are always going to be the direct point of contact with your end user – which in this case is the player – so they really do have an important role to play in shaping the perceptions surrounding your games and influencing people’s gambling behaviour. As such, they definitely need to be held to the same responsible gambling standards as operators and developers, though as I’ve said previously, companies can do their bit to ensure this is the case by only working with streamers they trust to promote their games the right way. I think if this due diligence is done, it’s easier to ensure there’s a consistently high standard across the board.”

FL: “Yes! The whole principle of RG standards is to protect players. It shouldn’t matter if that is while those players are on-site, playing a game, watching an ad or watching an influencer. The standard should all be exactly the same. No question.”

What steps can social media influencers and content creators take to ensure they are promoting responsible gambling?

LT: “They should take time to understand what it actually is and then consider how they can help promote safe gaming. Audiences a drawn to content around bonus hunts and big wins, but it’s important to balance that with safe gaming messages and even content that helps players to better understand how to stay in control of their play. Players trust influencers and content creators, so if they are promoting responsible gambling and telling players about the tools at their disposal to keep in control of their play then they are highly likely to use those tools and take a more considered approach to their online gambling.”

MP: “I think the main thing is to be transparent and always think about what type of viewers you’re sharing your content with and how that content is being promoted. Obviously when you’re advertising online gambling, you need to make sure that it’s only being seen by an age-appropriate audience, so filtering which followers can access it is clearly very important. Once you’ve done that, you need to pay close attention to the language you’re using and try to limit the use of terms like “life-changing winnings” that encourage reckless gambling. You also need educate players on why responsible gambling is important, rather than just promoting it simply because it’s a rule.”

FL: “They need to understand and follow the regulations. They’re all laid out by the UKGC, and influencers and content creators should read them, absorb them and follow them. The operators they work with will also have policies they have to adhere to. It’s all there in black and white.
Beyond that, I think influencers have a responsibility to provide accurate information, and to proactively educate their followers about how to gamble responsibly. They also need to be honest and open about their relationships with brands.”

Should Meta and other social media companies play an active role in controlling gambling advertising?

LT: “I think they should play an active role in prohibiting advertising from unlicensed brands and unscrupulous influencers and content creators. Right now, it’s still easy for unlicensed brands to promote their offerings through social media advertising, influencers and content creators, and for me, it’s up to these social media giants to do a better job of policing the advertisers and ads they allow on their networks. In some cases, ads are allowed to run before the account has been fully approved, and even if the platform blocks the account, another one is set up in its place and the ads resume. So, it’s not about controlling gambling advertising as such, but ensuring only approved advertisers are allowed and that those advertisers are running responsible ads.”

MP: “When it comes to advertising, Meta and other social media companies should be among the key gatekeepers for controlling what content ultimately goes out to players. There’s an obvious potential for harm if excessive ads are used or if they’re going out to underage audiences, so it’s really important that sites like Meta continue to enforce their policies and ensure that online gambling is always promoted in a responsible way. These institutions have so much data at their fingertips that it’s relatively easy for them to identify users who have higher risk potential, so it’s therefore incumbent on them to use this information in a proactive way that protects audiences.”

FL: “I think it’s critical that the influencers and content creators who use their platforms have the tools available to them to ensure they’re complying with regulations, and it’s the social media companies that need to provide this. These should be tools related to age restrictions and geo restrictions, as well as user-reporting so inappropriate content can be flagged. Everyone should be taking an active role.

“All companies have a legal and ethical obligation to ensure they do not contribute to harmful behaviours and social media platforms are no different.”