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How is iGaming Regulated Around the World? [EU, US, Asia, & Africa]

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iGaming is a term used to define online betting and gambling activities, whether casual or for real money. Its complicated regulatory framework makes understanding iGaming a challenge that advertisers must deal with before launching a campaign.

Here’s what to know about iGaming regulations across major markets, including:

  • The EU
  • Central and Eastern Europe
  • North America
  • Australia and New Zealand
  • Asia
  • South America
  • Middle East
  • Africa

The iGaming regulatory environment in the EU is highly developed; however, legislation varies significantly between countries.

In the United Kingdom, for instance, the iGaming industry has one of the most comprehensive regulatory frameworks overseen by the UK Gambling Commission. On the other hand, Malta is viewed as a leading iGaming-friendly country, in part due to its favorable regulatory climate. Germany and Ukraine are also huge markets in central and Eastern Europe.

The regulatory landscape in North America couldn’t be more different. In the United States, individual states can self-regulate online gambling, while Canada takes a unified approach. This approach enables provinces like Ontario to launch regulated iGaming markets.

Australia and New Zealand have different approaches as well, with Australia prohibiting domestic operators from launching online casinos but allowing sports betting. New Zealand, while limiting the operation of online casinos within its territory, permits its citizens to gamble on international websites.

Just as with Europe, Asia has a diverse regulatory landscape, with countries like China and South Korea maintaining strict prohibitions, while others like the Philippines fully embrace iGaming regulation.

In South America, the iGaming regulation landscape is constantly shifting, thanks to countries like Colombia creating comprehensive frameworks

Unlike other regions, the Middle East has restrictive policies towards online gambling, with a few exceptions. 

African countries appear to be behind the curve on iGaming regulation and frameworks. Nevertheless, nations like South Africa have taken steps to legalize online sports betting.

Given the vast array of legal frameworks or lack thereof in regions, understanding the world’s iGaming industry is challenges, especially when planning and launching gambling advertising campaigns

While emerging markets in South America, Africa, and parts of Asia provide potential opportunities, they are not without unique regulatory challenges. 

This article will provide essential insights into global regulations, enabling iGaming operators and advertisers like you to develop compliant and effective marketing strategies.

How is iGaming regulated in the EU?

Different countries in the EU have different regulations and laws in place, making it essential for advertisers to constantly be aware of the rules.

Country

Legal Status

Key Regulations

United Kingdom

Legal

- Must obtain a UKGC license.

- Advertising must be clear and responsible.

- Compliance with AML checks required.

Malta

Legal

- Requires MGA license.

- Responsible gaming measures and AML protocols mandatory.

Sweden

Legal

- Swedish license required.

- Strict advertising regulations focused on responsible gambling.

Norway

Partially Legal

- Online gambling mainly restricted to state-owned entities.

- Strict advertising rules apply.

Denmark

Legal

- License from DGA required.

- Advertising must not target minors and promote responsible gambling.

Finland

Partially Legal

- State-controlled; licenses required.

- Strict advertising regulations to protect minors.

Ireland

Legal

- License required under the Betting Act.

- Advertising must avoid misleading claims.

Understanding iGaming Regulations in The UK

UK online gambling laws are some of the strictest in the world, and that makes the UKGC license one of the most sought after. Online gambling is viewed as a mainstream leisure activity within the UK, and that has resulted in a plethora of options available to prospective players. 

With that in mind, the UK introduced the Gambling Act 2005, which provides a framework that ensures all gambling operations are conducted transparently and fairly. This Act is overseen by the UK Gambling Commission, which also ensures responsible gambling practices are enforced. 

Prospective iGaming operators must:

  • Utilize advanced customer verification tools and processes.
  • Provide options for self-exclusion and spending limits.
  • Adhere to strict advertising rules to inform consumers about the risks of gambling.

This comprehensive approach helps balance iGaming’s economic benefits with societal welfare.

Understanding iGaming Regulations in Malta

Malta holds a significant role in the iGaming jurisdiction thanks to the innovative and robust framework it began implementing in 2004. The Malta Gaming Authority was created by the Remote Gaming Regulations, making Malta the first EU member state to regulate online casinos. This legislation has now been replaced by the Gaming Act, a more updated and relevant piece of legislation.

There are various reasons why Malta and, by extension, the Malta Gaming Authority are viewed as leaders in the industry. For one, Malta’s regulatory landscape is more stable and developed than other countries, with the MGA providing clear guidelines to its licensees. 

The island nation also offers competitive gaming tax and corporate tax rates, which are typically lower than other jurisdictions. As one of the first states to create iGaming regulation.

Understanding iGaming Regulations in Nordic Countries 

While other nations in Europe already have existing frameworks and are moving to update them, the Nordic markets are lagging far behind. As it stands, Denmark, Norway, Finland, and Sweden do not have extensive iGaming regulatory policies. 

These nations, with the exception of Finland–which has no licensing system– do not offer licenses to iGaming operators outside their territory. Denmark does, however, allow its citizens to visit offshore iGaming platforms.

Nevertheless, there is increasing pressure from the iGaming industry for legislative reforms. The legislative arms of each country have been deliberating on introducing updated frameworks that closely match that of the rest of Europe, with Finland finally creating a licensing system in 2026. 

Both Norwegian and Danish lawmakers are proposing a bill that opens up their respective licensing systems to offshore entities. This goes to show that it is only a matter of time before the Nordic countries match regulations available elsewhere.

Summary of iGaming regulations in the EU

How is iGaming regulated in Central and Eastern Europe?

iGaming regulations in Central and Eastern Europe vary significantly from country to country, with some nations embracing a regulated market while others maintain stricter controls. The following table provides a snapshot of the legal status and key regulations in several countries across the region:

Country Legal Status Key Regulations
Germany Legal Interstate Treaty on Gambling, licensing required
Poland Partly Legal State monopoly on most forms of gambling
Czech Republic Legal Gambling Act of 2017, licensing required
Hungary Legal New licensing regime as of 2023
Ukraine Legal Legalized in 2020, high licensing fees
Russia Partly Legal Only sports betting allowed through licensed operators
Romania Legal Well-established regulatory framework

Germany, which has recently liberalized its iGaming laws, now allows licensing of online casino games, poker, and sports betting under the Interstate Treaty on Gambling (Glücksspielstaatsvertrag). 

Operators must obtain licenses from the national regulatory authority, Glücksspielbehörde, and adhere to strict rules regarding advertising, player protection, and responsible gaming.

Poland maintains a more restrictive approach, with online gambling largely controlled by the state monopoly. This situation has led to frustration among compliant operators who argue that relaxing laws could help the local gambling industry thrive.

The Czech Republic regulates its market through the Gambling Act of 2017, which introduced stricter licensing requirements for operators and imposed a tax rate of 23% on gambling activities.

Hungary has recently opened its market with a new licensing regime effective from January 1, 2023. Applicants must demonstrate at least five years of licensed online gaming experience within the European Economic Area. The regulatory framework includes financial obligations such as application fees, minimum registered capital, license fees, and taxes on gross revenue.

Ukraine legalized gambling in 2020 after an 11-year ban, allowing both online and land-based operations. However, the market faces challenges due to high licensing fees and a complex tax structure, which some argue could drive operators into the unregulated market.

Russia maintains strict regulations, with online gambling largely prohibited except for sports betting through licensed operators.

Romania has a well-regulated market, with online gambling legal and regulated. Operators must obtain a license from the National Gambling Office, and both local and foreign operators can apply for licenses.

Summary of iGaming Regulations in Central and Eastern Europe

How is iGaming regulated in North America?

Both the US and Canada have taken a similar approach to iGaming regulation. Rather than establishing a comprehensive framework at the federal level, legislation is left to the states and regions. 

That is, however, the similarities end as the United States’ current legislation prohibits online betting and casinos while letting states make their own decisions. Canada, on the other hand, has a laissez faire approach, letting each province and territory create frameworks that suit their overall policies.

Country

Legal Status

Key Regulations

United States

Partially Legal

- iGaming legality varies by state; seven states have legalized online gambling (e.g., New Jersey, Pennsylvania).

- Federal laws like the Wire Act and UIGEA set the framework, but states regulate individually.

- Tribal gaming is permitted under the Indian Gaming Regulatory Act (IGRA).

Canada

Legal

- iGaming is regulated at the provincial level.

- Provinces can operate online gambling sites and issue licenses.

- Responsible gambling measures and player protection are mandatory.

Understanding iGaming Regulations in the US

The United States regulates iGaming through a complex system where both state and federal governments play a role. While federal laws establish general guidelines, states decide their own gambling regulations. 

The Federal Wire Act of 1961 initially complicated online gambling legality by banning interstate sports betting via wire communications. This was clarified by the Unlawful Internet Gambling Enforcement Act of 2006, which prohibits financial institutions from processing transactions for illegal online gambling but leaves the definition of legality to individual states. This allows states to legalize iGaming and permit financial transactions within their jurisdictions.

Additionally, the federal government enforces anti-money laundering and consumer protection laws. States that have legalized online gambling include:

  • New Jersey
  • Nevada
  • Pennsylvania
  • Delaware
  • Michigan
  • West Virginia

Industry watchers believe it is only a matter of time before other states follow suit.

Understanding iGaming Regulations in Canada

Since the 1960s, Canada’s provinces have been able to introduce their own regulations regarding gambling. At the time, the focus was on lottery systems and land-based casinos. 

However, with the introduction of the internet, many provinces recognized the need to regulate online gambling platforms. The resulting effect is a country in which iGaming regulations differ from one province to another.

Due to the differences in regulations across provinces, Canada doesn’t have a federal licensing system. The federal government instead vests the authority to license gambling operators in the provinces.

Summary of iGaming regulations in North America

How is iGaming regulated in Australia and New Zealand?

Australia and New Zealand employ different regulatory approaches to iGaming without overarching policies.

Country

Legal Status

Key Regulations

Australia

Partially Legal

- Regulated under the Interactive Gambling Act 2001 (IGA).

- Online casinos and poker are prohibited; online betting is allowed with state licenses.

- Operators must comply with AML laws and have a local presence.

New Zealand

Legal

- Regulated by the Gambling Act 2003.

- Online gambling is permitted through licensed operators.

- Advertising must comply with responsible gambling standards.

Australia delegates iGaming regulation to state and territory governments, each setting their own laws. 

There’s no national regulatory body, but the Interactive Gambling Act 2001 bans offshore online casinos from serving Australian residents while allowing sports betting and lotteries. 

New Zealand regulates all iGaming under the Gambling Act 2003, which prohibits local iGaming sites except for TAB and Lotto NZ. Though New Zealanders can legally use foreign sites and are not taxed on winnings. 

Both countries emphasize consumer protection and responsible gambling, including advertising restrictions, to minimize harm and protect vulnerable populations.

Summary of iGaming Regulations in Australia and New Zealand

How is iGaming regulated in Asia?

iGaming regulations in Asia vary widely. Here's a quick overview of regulations across major markets in the region.

Country

Legal Status

Key Regulations

China

Illegal

- Strict prohibition on online gambling.

- New regulations limit in-game purchases and restrict gaming content.

- Minors can only play a limited number of hours per week.

Japan

Partially Legal

- Legalized integrated resorts with casinos in 2018.

- Strict regulations on casino operations, including entry restrictions for Japanese citizens.

- Long approval process for new resorts.

India

Partially Legal

- State-specific regulations; some states permit online gaming while others ban it.

- No uniform national law governing online gambling.

South Korea

Illegal

- Online gambling is prohibited, with severe penalties for operators and players.

- Only state-run lotteries and sports betting are allowed.

Philippines

Legal

- Regulated by the Philippine Amusement and Gaming Corporation (PAGCOR).

- Operators must obtain licenses and comply with local laws.

Vietnam

Illegal

- Online gambling is largely prohibited, with limited exceptions for state-run lotteries.

- Strict penalties for illegal gambling activities.

Malaysia

Illegal

- Online gambling is illegal, with severe penalties for operators and players.

- Some underground operations exist despite legal restrictions.

Indonesia

Illegal

- Online gambling is strictly prohibited, with harsh penalties for violations.

- Enforcement against illegal gambling activities is common.

Japan has strict regulations, generally prohibiting iGaming but has recently explored regulated integrated resorts focusing on lotteries and sports betting with a strong emphasis on consumer protection and preventing gambling addiction. 

The Philippines, contrastingly, has a robust and regulated iGaming industry, even issuing licenses to offshore platforms. India presents a fragmented regulatory landscape where states like Goa and Sikkim lead in offering regulated online gaming in the absence of a national framework. 

This piecemeal approach may prompt a more standardized federal regulation as iGaming demand grows.

Advertising challenges are significant in Asia due to strict regulations and cultural sensitivities. In many places, like Singapore, Malaysia, and some Indian states, online gambling is banned and iGaming advertisements are restricted or outright prohibited, leading to potential legal consequences for violations. 

Online advertising faces restrictions due to censorship or cultural sensitivities, as seen in countries like China and Japan.

Summary of iGaming Regulations in Asia

How is iGaming regulated in South America?

iGaming regulation in South America is as diverse as the countries in that region. Countries such as Colombia and Brazil are leading the region with proactive legislation. Other nations in the region aim to encourage market stability while protecting consumers. 

Thanks to the widespread adoption of mobile platforms, it is expected that more countries within the region will formalize their iGaming regulations.

A brief overview of regulation across major markets in the region:

Country

Legal Status

Key Regulations

Brazil

Partially Legal

- Sports betting legalized in 2023 with a new regulatory framework.

- Bill 3,626/2023 mandates licensing and compliance for operators.

- Online casinos remain illegal but may be regulated in the future.

Colombia

Legal

- eGaming Act 2016 establishes a licensing system overseen by Coljuegos.

- 15% tax on gross gaming revenue and player protection measures required.

Peru

Legal

- Online gambling is regulated, with operators required to obtain licenses.

- The government has established a legal framework for various forms of online gaming.

Chile

Partially Legal

- No specific iGaming legislation; general gambling laws restrict most online gaming.

- State-run lottery allowed to offer online games, but international operators face regulatory challenges.

Colombia is a leader in iGaming regulation, as it was the first country in the region to fully legalize and regulate online gambling in 2016. 

Through its regulatory body, the country provides a well-defined licensing framework for gambling businesses to offer sports betting, online casinos, and poker. The framework is a great way for the country to increase tax revenue generation while offering consumer protection.

While Brazil legalized online sports betting in 2018, full regulations are still being developed. Other countries, such as Chile and Peru, have also legalized iGaming; however, the framework needed is under development.

How is iGaming regulated in the Middle East?

While legalized iGaming is rare in the Middle East, there are countries that allow it in limited forms. Morocco and Lebanon offer the most liberalized iGaming laws, however, these fall short of frameworks developed in other regions of the world. Here's what iGaming regulations look like across major markets in the Middle East:

Country

Legal Status

Key Regulations

Saudi Arabia

Illegal

- All forms of gambling are strictly prohibited under Islamic law.

- Severe penalties for operators and players.

United Arab Emirates (UAE)

Partially Legal

- Generally prohibited, but a new regulatory body (GCGRA) was established in 2023.

- The first lottery license was awarded in July 2024, indicating potential future changes.

Turkey

Illegal

- Online gambling is banned, with severe penalties for violations.

- Only state-run lottery and sports betting are permitted.

Egypt

Illegal

- Gambling is largely prohibited, with limited exceptions for state-run lotteries.

- Strict penalties for illegal gambling activities.

Lebanon

Partially Legal

- Online gambling is not explicitly regulated; some forms of gambling are allowed.

- International operators may target the market despite regulatory ambiguity.

Kuwait

Illegal

- All forms of gambling are prohibited, with strict enforcement against illegal activities.

- Severe penalties for operators and players.

As earlier stated, there is no online betting permitted throughout the Middle East, and most countries have shown little interest in changing this. This is down to cultural and religious reasons—land-based casinos are also illegal in most of the region. 

Nevertheless, these laws haven’t stopped citizens from placing bets at foreign sites.

How is iGaming regulated in Africa?

Here's what to know about iGaming regulations across major markets in Africa:

Country

Regulatory Status

Advertising Considerations

South Africa

Regulated at provincial level

Restricted to of-age participants

Kenya

Betting, Control, and Licensing Board. To be replaced by new regulator

Responsible gambling message required on all campaigns

Nigeria

Regulated by the National Lottery Regulatory Commission. Supplemented by state lottery boards

Responsible gambling message required. 

The iGaming landscape in South Africa, Kenya, and Nigeria is currently experiencing rapid growth. This growth is driven by increasing internet penetration, smartphone adoption, and a young population.

South Africa has a complicated but regulated industry. While each province regulates and drafts licenses to operators within its jurisdiction, the National Gambling Board oversees the sector, ensuring operators comply with strict regulations.

Kenya has become a major iGaming hub in East Africa, thanks in part to sports betting. As a result of novel mobile payment systems, the country’s iGaming industry has experienced exponential growth. However, the industry is plagued with increased regulatory scrutiny and taxation, slowing down said growth.

Nigeria’s iGaming industry is booming, with the country’s population providing a large pool of potential players. While the National Lottery Regulatory Commission oversees the sector, there are challenges with regulatory enforcement and the shutdown of illegal operators. 

What should advertisers know about regulations in the global iGaming market?

With the iGaming market projected value sitting at $97 billion for 2024, advertisers need to be aware of the differing regulations across various regions. Policy ignorance cannot be excused, particularly when the relevant regulatory bodies provide licenses.

Some nations allow all forms of online gambling, while others restrict or outrightly ban certain activities like sports betting or online casinos. Understanding these frameworks is essential to avoid operational shutdowns, reputational damage, or heavy fines.

iGaming advertisers should also be familiar with the specific requirements in each market they aim to operate in. For instance, the UK Gambling Commission is one of the most stringent regulators, mandating operators to provide responsible gaming messages, clear advertising, and restrictions on targeting certain high-risk groups.

How do licensing requirements affect advertisers?

Licensing requirements directly determine where and how iGaming advertisers can promote their gambling platform. In regulated markets, these advertisers must ensure that only licensed operators are promoted. 

For instance, in the US, where regulations vary by state, advertisers need to be extremely careful when advertising. To this end, they need to only promote online betting in states where iGaming is legal.

Some regulators, like the UKGC, also have guidelines concerning gambling advertisements. For one, targeting at-risk groups or minors is prohibited. iGaming advertisements are also prohibited before Watershed (a time where minors might be watching TV). 

For jurisdictions that don’t have clearly defined guidelines, typical advertising concerns apply. Content restriction rules, such as not targeting minors and vulnerable individuals, apply.

Many other jurisdictions also require that iGaming adverts not exaggerate winning potential. Responsible gambling messages, such as self-exclusion options and addiction help service information, must be included in adverts. Failure to do so could result in shutdowns, fines, or withdrawal of license.

What are the risks of advertising in gray or unregulated markets?

The risks of advertising iGaming in gray or unregulated markets include:

  1. Legal consequences: advertisers may face fines, legal action, or operational restrictions if iGaming becomes criminalized in these markets in the future.
  2. Reputation damage: Brands risk damaging their reputation and creating negative perceptions among consumers if they fail to implement responsible gambling measures, even when not required by law.
  3. Platform policy violations: Advertisers may struggle to comply with the strict policies of major advertising platforms like TikTok, Facebook, and Google, which heavily regulate or restrict gambling-related ads.

What are the best practices for iGaming advertising in a complex regulatory environment?

Navigating the iGaming advertising landscape requires a strategic approach to comply with various regulations and consumer protections. Here are key best practices:

  • Understanding Regulatory Landscape: Stay informed on regional regulations, ensuring your campaigns are compliant in both regulated and unregulated markets.
  • Adhering to Responsible Gambling Initiatives: Promote responsible gambling by including messages about self-exclusion, addiction prevention, and safe play in your ads.
  • Complying with Platform-Specific Ad Policies: Each platform (Google, Facebook, etc.) has specific rules for gambling ads; ensure your campaigns meet these requirements.
  • Use Less Aggressive Marketing Tactics: Avoid exaggerating potential wins or outcomes. Instead, promote gambling as a responsible entertainment activity.
  • Utilize Geo-Targeting on Blockchain-Ads: Use specialized ad networks like Blockchain-Ads for geo-targeting. That’ll help you focus ads in regulated areas, reducing legal risks in unregulated regions. 

Which Emerging Markets Should Advertisers Watch?

iGaming advertisers should pay close attention to several emerging markets due to their current and forecasted growth. Here are a few:

  • Colombia: Implemented a regulatory framework for iGaming, leading to significant market growth.
  • Peru: Regulated its online gambling market in 2022, resulting in substantial growth.
  • Brazil: A massive population and developing legislative environment make Brazil a critical market to watch.
  • Kenya: Increased mobile payments and internet access are driving growth in the iGaming sector.
  • South Africa: A growing market supported by improved connectivity and mobile gaming adoption.
  • Nigeria: Rising internet access and mobile payments are boosting iGaming activity in the country.
  • Canada (Ontario): After regulating its iGaming market, Ontario generated about $2.7 billion in revenue in its second year of operation.

Conclusion: Key Takeaways for iGaming Advertisers

The iGaming industry is poised for exponential growth, particularly in certain regions of the world. With that, advertisers need to understand that navigating the iGaming regulatory landscape requires a thorough approach. 

This means recognizing which markets offer clearly defined policies and regulations. It also means understanding which markets can be classified as grey markets. In all, when advertising, iGaming advertisers must consider licensing requirements and other factors like responsible gaming, and more.

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Адам Джордан
Генеральный директор маркетингового агентства Social Kick