New draft bill proposing stricter rules on marketing of gambling activities
The draft bill forms part of the political agreement "Spilpakke 1: Et mere ansvarligt spilmarked" from October 2025 and is designed to strengthen consumer protection and reduce gambling addiction, particularly among minors and vulnerable groups.
New restrictions on marketing of gambling
The current Section 36 of the Gambling Act governs the marketing of gambling, including lotteries, combination games and betting activities, e.g. sports betting.
Section 36 currently requires for example that the chances of success are marketed accurately, that the marketing is not targeted at minors, and that the marketing does not suggest that gambling is a solution to financial or social problems.
The draft bill will entail that marketing of gambling may also not:
- suggest that gambling has contributed to success,
- that the marketing is not in any way appealing to minors (e.g. by using animated characters or actors that appeal to minors etc.)
- depict gambling as a lifestyle, priority, or a natural part of belonging to a community/social group,
- use authority figures, including public figures, athletes or influencers, or
- feature persons under the age of 25, including both real persons and fictive persons appearing to be under the age of 25.
As for authority figures, the draft specifies that a person with more than 10,000 followers on a social media platform, or more than 100,000 views across platforms within a recent period of time, will always be considered an "authority".
Additionally, new regulation on the display of gambling ads is proposed, prohibiting such ads from being displayed:
- in public transport or in connection with public transport, e.g. on busses, stations etc.,
- within 200 meters of schools or youth education institutions, except for areas not readily available to the public (e.g. the inside of stadiums or inside of shops), or
- 10 minutes before, during or 10 minutes after the transmission of live sports events.
Further, if a third party is engaged to market gambling activities, payments to such third party may not be commission-based depending on players' spending or losses.
Thus, the draft bill introduces significant additional restrictions on the marketing of gambling, which will affect both the content and display of gambling ads, while also potentially impacting contracts with third parties preparing or displaying such ads.
Violation of Section 36 is punishable by a fine for anyone violating the provisions, i.e. not only for the gambling provider, but also for third parties who for example display the ads.
Other amendments, including on responsible gambling
The draft bill also proposes several other amendments, including strengthening of the Gambling Authority's enforcement options.
A new Section 36a on responsible gaming is also proposed. Under this new provision, license holders will be required to monitor player behaviour and to act immediately if a player shows signs of problematic gambling behaviour or gambling addiction. License holders must:
- establish written internal rules and procedures on responsible gaming,
- continuously evaluate the effectiveness of the measures implemented, and
- ensure that relevant employees, retailers and employees at retailers receive adequate training on identifying and responding to problematic gambling behaviour and addiction.
Consultation deadline and expected effective date
The bill is scheduled to take effect on 1 July 2026. However, several provisions, including the amended Section 36 and the new Section 36a on responsible gaming, are subject to an exemption and will instead take effect from 1 January 2027.
Plesner is closely monitoring the legislative process and is available to assist to ensure timely compliance with the new requirements.