Italy: AGCOM Defines the Line Between Responsible Gambling Campaigns and Hidden Advertising

Key Points

• AGCOM published Resolution 200/26/CONS on 10 August 2026, setting binding content, branding and data rules for all responsible gambling communications by Italy’s licensed operators.
• The resolution addresses a direct conflict created by Legislative Decree 41/2024, which requires operators to spend 0.2% of net revenues on responsible gambling campaigns while the Dignity Decree’s advertising ban remains fully in force.
• AGCOM has deliberately excluded infotainment from this resolution and has announced a separate review of its 2019 advertising guidelines, which is expected to become the most consequential regulatory debate in Italy’s gambling sector in the near term.

Resolution No. 200/26/CONS by AGCOM was issued on 10 August 2026. It was adopted by the Council of the Authority on 29 July and came into force the next day. It serves as a complementary document to the existing responsible gambling guidelines and does not revive gambling advertising in Italy. The main goal of this document is to determine when a responsible gambling message is really preventive, and when it becomes disguised brand promotion.

A Conflict Built Into the Law

This regulatory tension that gave rise to the agreement exists within Legislative Decree 41/2024, Italy’s 2024 online gambling law reform. Article 15 of this legislative decree mandates that each of the 46 operators that operate in Italy must allocate 0.2 per cent of its annual net revenues, up to one million Euros, to responsible gambling communications campaigns. Under certain circumstances, the same article allows the operators to conduct the campaign using their own brand/logo.

That obligation sits in direct tension with the 2018 Dignity Decree, which prohibits any form of advertising, including indirect advertising, related to games or bets with cash prizes. AGCOM’s 2019 Resolution 132/19/CONS implemented that ban. However, it predated the new licensing framework and did not account for a regime where operators are legally required to communicate publicly about gambling in a protective context.

DLA Piper’s legal analysis, published in April 2026 ahead of the finalised guidelines, described AGCOM as needing to define a narrow “safe zone” where brand-bearing campaigns can exist without breaching the advertising ban. Resolution 200/26/CONS converts that concept into binding rules.

What a Campaign Must Not Contain?

The resolution sets a single non-negotiable standard: one prohibited element makes an entire campaign non-compliant. Operators cannot offset a problematic reference with strong prevention messaging elsewhere in the same communication.

Prohibited content includes references to winnings, bonuses, odds, jackpots, financial incentives and reward mechanisms. Screenshots of gambling platforms, interfaces and account areas are equally excluded. Visual elements associated with the gambling experience, such as slot-style animations, playing cards, dice and roulette imagery, are also banned, as are audio effects linked to jackpots or wins. Calls to action are prohibited, whether explicit or indirect. A prevention message that leads a user towards a commercial gambling service fails the test, regardless of how it is phrased.

AGCOM will judge campaigns on the overall impression they create, not on individual wording. That is a broader standard than a simple content checklist.

How Operator Logos Can Appear?

Operator branding is one of the most commercially sensitive areas the resolution addresses. AGCOM confirms that a licensee’s logo may appear in responsible gambling campaigns, consistent with what Article 15 of Legislative Decree 41/2024 allows. Its role must be limited to identifying the operator, not promoting it.

The guidelines specify how that distinction plays out in practice. The logo must not be the most prominent element of the communication. Placing it to the side or in a corner, keeping it small relative to the prevention message, avoiding animations or enlargement effects, and limiting its screen time in audiovisual content are all cited as indicators that branding remains genuinely secondary. Where an operator’s brand name is also the name of a specific gambling product, AGCOM considers its use entirely incompatible with responsible gambling communication.

Digital Links and the Data Governance Obligation

The rules on digital links are among the strictest in the resolution. QR codes, URLs and clickable links may not lead to gambling websites, apps or bonuses, whether directly or through a sequence of intermediate steps. AGCOM permits links to dedicated player protection pages hosted on a licensee’s site, but those pages must display no operator logo, carry no promotional material and provide no navigation path to a gambling area or account.

The resolution also introduces a data governance obligation. Any data collected through player protection tools, including spending limits and self-exclusion, cannot be used to profile users for commercial purposes, target them with advertising, or build predictive models of their gambling behaviour. Operators must demonstrate technical segregation between their player protection systems and the commercial sections of their platforms. A policy document asserting that separation exists is not sufficient. This directly links responsible gambling compliance to how operators manage personal data, alongside the EU’s broader data protection framework.

Celebrities and Vulnerable Groups

AGCOM does not ban celebrities or influencers from responsible gambling campaigns outright. Athletes and well-known figures may extend a campaign’s reach, but their presence must not contribute to normalising gambling as an ordinary social activity. Their involvement is permissible only where player protection messaging takes clear precedence and the campaign remains focused on risk awareness.

Operators should also note a specific restriction on ambassadors. AGCOM advises against using individuals who are already associated with other activities in which the licensee’s brand appears. What matters is the relationship between the individual, the brand and the campaign message, not simply who appears on screen.

For vulnerable groups, requirements are stricter. The 18-to-24 age group and people aged over 65 are both flagged as requiring tailored communication approaches. Campaigns targeting the 11-to-17 age groups must be delivered exclusively in educational and institutional settings, structured specifically to prevent any risk of normalising gambling among young people.

Infotainment: Left Outside This Resolution, but Not Forgotten

The most significant gap in Resolution 200/26/CONS is deliberate. AGCOM acknowledges the issue of infotainment directly: informational websites linked to licensees, brand identifiers built around domain extensions such as .sport, .live or .news, and brand visibility on football shirts and sports media. It accepts that these formats can function as promotion or serve as a route around the advertising ban. AGCOM then states clearly that this resolution does not address them. Infotainment remains subject to Article 9 of the Dignity Decree and the 2019 Resolution 132/19/CONS.

Following concerns raised during the consultation process, AGCOM states it considers a review of those 2019 guidelines necessary “in the near term.” That review will cover the territory that matters most to Italy’s sports and media industries, including the question of whether brand-linked informational formats constitute disguised advertising under existing law.

Industry pressures have been quite substantial. In March 2025, Italy’s Senate passed a resolution urging the government to review the Dignity Decree due to its lack of efficiency in fighting gambling addiction and due to the competitive disadvantage of Italian football clubs compared to other football clubs in other EU countries. Minister of Sport Andrea Abodi confirmed talks with Serie A, broadcasters and sports federations about changing the sponsorship regime, including an option of charging 2% of the income from betting on football. The Dignity Decree has not been repealed yet.

Expert Analysis

Resolution 200/26/CONS sets clear rules for a narrow category of communication but does not resolve the deeper structural problem it was created to address. Italy’s 46 licensed operators are legally required to spend money communicating publicly about their gambling services in a preventive context, while almost any other form of operator communication remains prohibited under the advertising ban. The resolution defines where that permitted space begins and ends, but compliance is not a one-time sign-off. AGCOM will not pre-approve campaigns; it will review them after publication, judging each against content, format, link structure and distribution.

Operators with integrated systems in which player behaviour data flows across marketing and player protection functions will also need to demonstrate genuine technical separation between those two areas, not just a policy document asserting it exists.

The larger question is what follows this resolution. The forthcoming review of the 2019 advertising guidelines will determine whether Italy’s regulatory framework can maintain a workable distinction between brand communication and gambling promotion in a market that generated approximately €5 billion in online gross gaming revenue in 2024. That review, covering infotainment, sports media and indirect brand visibility, is where Italy’s next significant gambling advertising decision will be made.