In our previous articles, we explored Truthful and Non-Misleading Advertising (Standard 2.04) and Inducements & Bonus Advertising (Standard 2.05). Another important area of Ontario’s regulatory framework is the protection of minors and vulnerable individuals.
This is more than a compliance requirement. It reflects a commitment to responsible gambling and player protection, helping ensure that gaming remains a form of entertainment for adults.
Ontario’s regulated iGaming market was built on principles of accountability, transparency, and social responsibility. Operators, suppliers, and affiliates all play a role in supporting these objectives.
AGCO Standard 2.03
2.03 Advertising, marketing materials and communications shall not target high-risk, underage, Self-Excluded Persons, or Centrally Self-Excluded Persons to participate in lottery schemes, shall not include underage individuals, and shall not knowingly be communicated or sent to high-risk players. (Also applicable to Gaming-Related Suppliers)
Requirements – At a minimum, materials and communications shall not:
- Be based on themes, or use language, intended to appeal primarily to minors
- Appear on billboards or other outdoor displays directly adjacent to schools or other youth-oriented locations
- Use or contain cartoon figures, symbols, role models, social media influencers, celebrities, or entertainers likely to appeal to minors
- Use active or retired athletes who have agreements with operators or suppliers, except for responsible gambling messaging
- Use individuals who are, or appear to be, minors to promote gaming
- Appear in media or digital environments directed primarily to minors or where minors are the primary audience
- Exploit the susceptibilities, inexperience, or lack of knowledge of potentially high-risk individuals, or otherwise extol the virtues of gaming
- Entice or attract potentially high-risk players (with measures required to limit marketing to known high-risk players)
Guidance: Where cartoons are used, they may not primarily appeal to minors.
Beyond Compliance
For many affiliates, compliance with this standard may require reviewing not only written content, but also website design, advertising placements, social media activity, email marketing practices, and audience targeting strategies. Protection of minors and vulnerable individuals should be considered throughout the entire marketing journey.
Ontario’s standards recognize that some individuals may be more vulnerable to gambling-related harm than others. This can include people experiencing financial difficulties, emotional distress, or other personal circumstances that may increase the likelihood of impulsive gambling decisions.
The Importance of Ontario’s 19+ Requirement
Affiliates promoting Ontario-licensed operators should also remember that the legal gambling age in Ontario is 19+.
While some international or grey-market websites may reference gambling ages of 18+, Ontario’s regulated market requires clear communication that gaming products are intended only for individuals who are 19 years of age or older.
Including appropriate 19+ messaging helps reinforce responsible gambling principles and provides clarity for users visiting affiliate websites.
What This Means for Affiliates
Considerations should include:
Key considerations should include:
- Ensuring images used throughout a website do not appeal to minors
- Maintaining an overall design and content presentation intended for adult audiences (19+)
- Targeting advertising placements to appropriate 19+ audiences
- Ensuring social media activity and targeting align with 19+ requirements
- Including a clear 19+ notice on websites to confirm the intended audience
- Using language in reviews, rankings, and content that does not appeal to or target vulnerable individuals
Even content that appears compliant at first glance may raise concerns if it unintentionally appeals to younger audiences or vulnerable individuals.
Affiliates using email marketing, community marketing, or other direct communication channels must exercise additional care. While affiliates generally do not know whether an individual has self-excluded or may be experiencing gambling-related harm, marketing practices should always be designed with responsible audience targeting in mind.
The objective is not simply regulatory compliance. Affiliates also play an important role in contributing to a safer and more responsible gaming environment.
By creating content that is informative, responsible, and clearly intended for adult audiences, affiliates contribute to the long-term integrity of Ontario’s regulated iGaming market.
In our next article, we will continue exploring Ontario’s Marketing and Advertising Standards and how affiliates can apply them effectively when promoting licensed operators in Ontario.