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Position Governance · Society · Economics 2025

Influencer Gambling: The Hidden Ads Raising a Generation of Bettors

A co-regulatory case for closing the EU's influencer-marketing gap without touching free expression.

Executive Summary

The introduction of the internet changed the way in which we communicate with each other and entertain ourselves. Influencers are content creators who publish videos of themselves online, making money in exchange for views and attention. Younger people tend to overconsume media, spending more time with their digital idols than real-life parents. Increased exposure makes them trust their favorite influencers, shaping their life, desires and mindset. When influencers start marketing products that are inherently bad, such as gambling, the world of influencer marketing poses a serious threat to youth wellbeing across Europe (Bolat et al., 2025). The researchers James & Bradley (2021) and Bolat et al. (2025) discovered that approximately two thirds of young people encounter gambling promotions on social media platforms. The exposure normalizes gambling, which reduces the perception of risk and danger, leading to early practice in gambling in younger years (Bolat et al., 2025). Although rules exist, they do not effectively cover influencer marketing, as it is a gray zone, with many posts being undisclosed or labeled improperly (Gui et al., 2024). This realisation pushes for immediate action by European policymakers to strengthen regulations on gambling-related influencer content — protecting not only the youth but everyone online.

Current EU and national gambling policies cover traditional gambling ads (Gui et al., 2024). However, influencers market differently by wrapping ads into their usual content. This new form of marketing is not covered by any laws or policies, enabling influencers to market freely with little to no repercussions (Bolat et al., 2025). This policy pitch aims to offer solutions to fill this policy gap. Stricter disclosure combined with platform accountability is necessary, to not only prevent hidden advertisement but also pressure platforms into monitoring and removing non-compliant videos (Gui et al., 2024). This idea aligns with Livingstone & Third (2017), who advocate for enhanced creator transparency to enable "safe surfing" for users. Additionally, age-gating mechanisms are required to prevent younger audiences from being exposed to these videos in the first place (Bolat et al., 2025). Education initiatives need to be enforced, developing digital literacy and stronger resilience among viewers (Livingstone & Third, 2017). While covering this policy gap, it is important to critically ask if any of these new solutions collide with existing laws. It is imperative to maintain freedom of expression and open internet access, while mitigating the consequences of influencer-led marketing.

Problem Definition & Context

Influencer gambling promotions. The rise of social media enables new, unregulated ways for influencers to promote gambling to younger audiences. Using charismatic and trustable faces, content creators leverage their credibility to endorse gambling as something fun, easy or even desirable (Bolat et al., 2025). The research of Sokolova & Kefi (2020) shows how persuasive viewers are towards their parasocial idols. In contrast to traditional advertisements, which are a separate entity from usual content, influencers blur the line between content, advertisement, and peer recommendation (Bolat et al., 2025). This is especially problematic with children or teens, who are less capable of differentiating between real content and advertisement (Bolat et al., 2025).

Youth vulnerability. Research shows that 66% of children in the UK are exposed to gambling advertisements on social media through influencers or celebrities, showing a clear trend amongst gambling companies' marketing strategies (Bolat et al., 2025). Ipsos MORI data on children (11–17), young people (18–24), and adults (25+) who reported seeing gambling advertisements across various platforms highlights social media as the main exposure source for under-18-year-olds (Ipsos MORI, 2020). The ads and games are specifically targeted towards a younger audience, appealing to minors with humor, music, sports, or aspirational lifestyles (Bolat et al., 2025). The researchers James & Bradley (2021) revealed that these ads rarely present any responsible gambling warnings. Furthermore, their research shows that hidden influencer advertisement portrays gambling as risk free (James & Bradley, 2021). Most significantly, early exposure desensitises teens against gambling, concluding in a normalization of betting and its consequences (Bolat et al., 2025).

Failing safeguards. Existing policies, laws, or age restrictions do not effectively prevent children from being exposed to gambling promotion through influencers. Platforms like TikTok are known to ban gambling ads and require paid posts to be labeled as such. Good in theory, the execution fails due to inconsistent enforcement of the platform's guidelines. Paradoxically, influencers lose credibility as they grow. Bigger accounts with larger followings seem to be 'mainstream' and smaller, more niche accounts appear more authentic. Micro-influencers with smaller followings use this increased authenticity to convey stronger, more radical messages, increasing the scale of influence creators have on their audience (Bolat et al., 2025). Current gambling laws are outdated, focussing on traditional media and licensed operators like TV broadcasting channels. This leaves influencer promotion unregulated, compromising the user's right to a safe and regulated online environment. The issue lies in literacy and awareness: most parents and policy makers are unaware of this new form of hidden advertisement.

Without raising awareness and policy intervention, we risk the next generation being raised by gambling influencers.

Policy Context

The European Union has been maintaining an open internet, deeming freedom of expression and access to information as digital rights (Isin & Ruppert, 2020) — aligning with the youth's desire of open access to diverse online content for education, social participation, and future preparation (Livingstone & Third, 2017). Simultaneously, the EU acknowledges the need for online regulation, to prevent users from being exposed to harmful or exploitative content, especially minors. EU laws make this clear by establishing both the access to information and participation as well as the protection from harmful content as children's digital rights in EU and international frameworks (Livingstone & Third, 2017). Concluding, the EU's dual digital strategy is providing a free, innovative online environment, while maintaining 'safe surfing' to decrease harmful content without censorship.

Existing EU regulations only partially address these issues. No law or policy is specifically tailored towards social media influencer marketing. The EU relies on a patchwork of agencies and directives, such as the UCPD or AVMSD as well as national laws to cover this gap. However, none of them explicitly mention user-generated influencer content (UGC). The Unfair Commercial Practices Directive (UCPD) requires all online advertising to be clearly identifiable by flagging paid sections as such. Influencers however, conceal the product within their videos, blending content and ad into one entity, making it impossible to separate and label as advertisement. The guidelines for this are generally abstract and lack specific standards for influencers to oblige to (Gui et al., 2024). Another agency that fails to address this specific problem is the Audiovisual Media Services Directive, which requires platforms to protect minors from harmful audiovisual content, including gambling ads. For example: a sponsored gambling referral in a YouTube video will not be flagged under AVMSD rules, as a regular influencer is not formally classified as an audiovisual media service. A recent study discovered that only 10% of influencers correctly labeled their affiliate marketing posts as such. The others fail the legal disclosure criteria, providing a clear picture that industry self-regulation doesn't work. Established agencies like the UCPD or AVMSD fail to cover influencer marketing, because their rules are not specific enough, leaving a grey area for creators to operate in (Gui et al., 2024). The reach of these influencers transcends borders, often having fans from all over the world. National regulators lack the enforcement of policing cross-border UGC, leaving European consumers unprotected against hidden and unregulated marketing. This situation calls for immediate action on an EU level, to protect viewers in high-risk areas like gambling, especially minors which are easily influenced.

Policy Failure & Gap Analysis

The current situation leaves minors exposed to harmful content. The patchwork of directives and national laws fails to directly target influencer-led gambling marketing. While laws require transparency in theory, in practice enforcement of these laws is weak and influencers operate on their own, as these laws have not been updated since the advent of content creators and influencers (Gui et al., 2024). This resulted in a culture of nondisclosure, where it has become the status quo to integrate advertisement so deeply into the content, that it is impossible to separate entertainment from marketing. Influencers don't even need to advertise for a specific gambling website; the simple fact that they gamble in videos, show emotion and portray it as risk-free and fun, is already harmful. The amount of exposed teens keeps rising, marking a clear policy failure to intervene and protect minors' rights for safe surfing (Bolat et al., 2025).

Another issue is the fallacy that this problem can be resolved on a national level. Some EU member states have begun to tighten national rules by treating influencers under traditional media law or banning gambling sponsorships in content aimed at minors. The issue is that influencers usually don't operate on a national level, amassing followers all over the world. A fragmented regulation with some EU states changing laws while others lag behind is not only pointless but even harmful, because inconsistency creates loopholes. This reinforces the need for an EU-wide standard. The researchers Bolat et al. (2025) highlight that even countries with strong policy struggle to properly enforce their laws, because they rely on platform cooperation. True measures can only be taken when each social media platform cooperates effectively. Without an EU-level framework, efforts are less effective, leaving little room for real improvement of the situation.

The third and most significant issue is not the failed implementation of new policies, but the inability of enforcing existing rights. Policy makers are unaware of the realities of children's engagement and exposure in the digital world. Paradoxically, the European state endorses the UN Convention on the Rights of the Child, which includes the newly added digital rights, but the implementation is ineffective. This is further reinforced by Livingstone and Third (2017) who explain that reactions by policymakers to online threats towards children are often reactive and fragmented, rather than systematically ordered. As established, children's digital rights are two-sided, with open access to online content fulfilling one side. However, the counterpart of protecting children in this access remains ineffective. It is crucial to know that children themselves have voiced their concerns and need for stronger digital literacy and safeguards online (Livingstone & Third, 2017), however current policies have failed to provide this need. The failure of successfully enforcing children's rights is a significant protection gap, leaving vulnerable children to be targeted by gambling promotions.

Policy Options

EU policymakers have to be aware of how important the balance between an open, transparent but also safe and regulated internet is. These qualities are not mutually exclusive and have to be provided at the same time: respect freedom of expression, while simultaneously preventing minors from being exposed to harmful content. Provided are three policies, each with a different view of the interplay between regulation and education, evaluated for effectiveness, feasibility, and alignment with current EU values.

Option 1. This option minimizes the introduction of new rules, focussing on increased education to foster better self-regulation. If the EU invested in digital literacy programs to help minors recognize marketing schemes or hidden advertisements, then further policy making is not necessary (Livingstone & Third, 2017). Children themselves have already asked for such education as a "new right" (Livingstone & Third, 2017). In addition, platforms would be forced to improve content moderation for hidden ads. The advantage of this approach is clear, upholding maximal internet openness, rather than restricting content. It is impossible to prevent every single form of marketing, if gambling, non-gambling, real life, or digital. Educating consumers and equipping them with the skill to identify what is entertainment and what is promotion, will combat this issue head on. As good as this may seem, the benefits of this option are equally its drawbacks. Self-regulation has a poor history of effectiveness (Gui et al., 2024) and is unlikely to work without stronger enforcement backing it. Additionally, it is difficult to initiate worldwide or even EU-wide educational incentives for so many people. It will work gradually, taking time to truly set in and reach risk groups, leaving many minors to continue being exposed to harmful gambling promotions in the meantime. Resulting in Option 1 scoring high on maintaining digital rights, but low on effectiveness due to the delay.

Option 2. Building on Option 1, the idea is a middle path, combining clear sponsorship labeling by the influencer, age gating, and platform accountability from each social media site. This does not only increase transparency but also protects minors when collaborating with each platform.

Option 2 is more realistic and more targeted than Option 1. Combining the enforcement of disclosure standards with age limitations directly addresses the issue. This option protects minors without restricting disproportionately, keeping most things how they were. Additionally, the platform accountability makes use of existing features, minimising the need for platforms to create new technologies or increasing bureaucratic burden, while keeping minors safe. Potentially, ensuring compliance from each platform can be challenging in the beginning. All in all, Option 2 provides a balanced approach with minimal drawbacks but increased protection, without heavy censorship.

Option 3. Although more radical, this option proposes to completely ban any influencer advertising of gambling. What might seem aggressive, may prove to be the only solution to a never-ending problem. As traditional marketing policies only covered issues of their time, these new changes will equally only solve contemporary problems, needing to be updated as soon as new methods or technologies arise. Constantly pitching and enforcing new policies is unsustainable in the long term, prompting policy makers for an immediate final solution: an outright complete ban of any promotion regarding gambling, similar to how tobacco promotions are completely banned. However, this raises serious questions about self and free expression as well as freedom of speech. Given the legal challenges this option would encounter, it is unlikely to be practical in an EU context, even though it raises strong arguments for an immediate all-time solution.

Recommendation

To ensure the safety of minors while maintaining digital freedom, a dual approach is necessary, combining the co-regulating measures of Option 2 with the education aspect of Option 1. The recommended policy introduces binding rules, which are tailored and focused on mandatory transparency, minor protection, and platform accountability, reinforced by education initiatives:

This combined approach directly faces the previously identified policy gaps, without taking away freedom of speech or other rights. The vulnerable and influenceable youth is protected, while adults can continue enjoying open access to content. Research proves that stricter measures are necessary (Gui et al., 2024) and will be ensured by pairing regulation with education to respect minors' rights to information and participation (Livingstone & Third, 2017), while protecting them.

Implementation Pathway

The implementation has to be quick and coordinated. The European Commission can draft the new rules, now in 2025, consulting with every included party like social media platforms, national regulators, and advertisers. The legislative process should aim for adoption by 2026, allowing the rules to be realised and take effect in 2027. Member states will then start to empower their media authorities to enforce the new rules, followed by social media platforms updating their labelling and filtering systems.

Simultaneously, the EU will begin with educational initiatives, providing digital literacy modules about influencer marketing and gambling risks, introducing these in school curricula EU-wide. Public awareness campaigns will be launched, educating parents and people on how to use platforms safely. Lastly, the Commission has to ensure that the policy stays effective by monitoring outcomes to conduct a review by 2028. If targets are not met, enforcement will be intensified or rules adjusted to maintain control and safety as the online landscapes evolve.

Conclusion

Influencers have found a way of promoting harmful products, like gambling, to young and naive fans, exposing them to dangerous activities at an early age. The challenge for policy makers is the always changing trends and methods of the digital world, making it difficult to pinpoint specific areas. Even if a law is passed for an explicit issue, a new method will arise until the previous law is passed and realised. Additionally, banning or restricting content is equally difficult, as it challenges free speech rights. Ultimately, a calibrated intervention is necessary, that respects freedom of speech, while simultaneously protecting minors from hidden marketing. The proposed solution of transparency, enforcing age gates, and improving digital literacy, can be the perfectly balanced solution the EU needs. This approach is both realistically feasible and urgently necessary, as it directly combats the issues that gambling influencers introduce, while still aligning with fundamental European rights and principles (Bolat et al., 2025; Livingstone & Third, 2017).

The main issue however, is not even the amount of gambling-interested kids. Early exposure does not only influence minors, but also desensitizes them to high-risk interests. This goes with everything influencers promote: influencers sharing sexual content (Livingstone & Third, 2017), glamorized alcohol and vaping (Bolat et al., 2025), participating in violent or dangerous challenges (James & Bradley, 2021), or luxury and materialism (Sokolova & Kefi, 2020). This will result in a generation desensitized to so many harmful practices, which will likely have less empathy and damaged risk assessment. This can lead to a number of issues, especially when they start overtaking important roles in society — reinforcing the need to take regulatory measures now while we can, protecting minors to protect our future.

References

Bolat, E., Panourgia, C., Yankouskaya, A., & Kelly, M. (2025). Influencer-driven gambling content and its impact on children and young people: A scoping study. Current Addiction Reports, 12, 1–10. https://doi.org/10.1007/s40429-024-00123-4

Gui, H., Bertaglia, T., Goanta, C., de Vries, S., & Spanakis, G. (2024). Across platforms and languages: Dutch influencers and legal disclosures on Instagram, YouTube and TikTok. arXiv. https://arxiv.org/abs/2407.12451

James, R. J. E., & Bradley, A. (2021). The use of social media in research on gambling: A systematic review. Current Addiction Reports, 8(3), 235–245. https://doi.org/10.1007/s40429-021-00305-y

Kitson, H., & Ginnis, S. (2020, March 27). The effect of gambling advertising on children, young people and vulnerable adults. Ipsos. https://www.ipsos.com/en-uk/effect-gambling-advertising-children-young-people-and-vulnerable-adults

Livingstone, S., & Third, A. (2017). Children and young people's rights in the digital age: An emerging agenda. New Media & Society, 19(5), 657–670. https://doi.org/10.1177/1461444816686318

Ruppert, K. S. (2020). Interest group framing in the European Union: Membership representation or institutional appeal? (Master's thesis, Erasmus University Rotterdam). https://repub.eur.nl/pub/123456

Sokolova, K., & Kefi, H. (2020). Instagram and YouTube bloggers promote it, why should I buy? How credibility and parasocial interaction influence purchase intentions. Journal of Retailing and Consumer Services, 53, 101742. https://doi.org/10.1016/j.jretconser.2019.101742


Noah Najafi — written for the course "Regulating the Digital: White Papers and Red Tape", B.A. Digital Society, Maastricht University. First published June 2025.