The Danish Gambling Authority (DGA) has released updated versions of two key guidance documents that direct how gambling and betting operators must manage their promotions.
These amendments, published on the regulator’s website, provide more precise regulatory advice to gambling operators.
Specifically, the regulator has released Version 3.0 of its “Guidance on Duty of Disclosure in the Marketing of Gambling”, and Version 5.0 of the “Guidance on Sales Promotions”.
One salient update in the area of marketing is a clarification of the duty of disclosure across multiple marketing channels.
The guidance reaffirms that all licensed operators must present specific information in their marketing materials.
This includes the minimum legal age to gamble, the existence of the national self-exclusion register (ROFUS), and the availability of the responsible gambling helpline StopSpillet.
Additionally, use of the Gambling Authority’s licensing mark is required, and each element must be presented in a legible and prominent manner.
The guidance also expands and clarifies how disclosure rules apply across different advertising formats. For instance, it sets out that SMS and podcast marketing must include all critical information, such as age limits and references to responsible gambling services.
Banner ads must, at a minimum, display age requirements. When using social media, operators must ensure their profiles and all promotional posts fulfil the disclosure obligations, not just their main web platforms.
This framework ensures that gambling-related information isn’t obfuscated, even in formats where space is limited or where visual assets dominate.
New guidance issued on promo mechanisms
Meanwhile, Version 5.0 of the “Guidance on Sales Promotions” revises and expands the definitions of several promotional mechanisms.
The guidance offers explicit categorisation and rules for betting challenges, boosted odds, cashback offers, free bets, tournaments, and loyalty programs.
Each of these promotional tools is subject to stringent evaluation to determine whether it constitutes a sales promotion or is considered part of the regular game structure.
For example, boosted odds are now defined in greater detail. If a boosted odds offer results in a theoretical return-to-player percentage above 100%, it will be usually be treated as a sales promotion and therefore subject to promotional rules.
Even when this cannot be calculated, such as in single-outcome bets like “first goal scorer”, a contextual assessment will determine whether it qualifies as a promotion.
If promotions are only accessible to new customers or specific user segments, they will still be subject to the full set of regulatory controls, including a 1:1 ratio requirement between deposit and reward.
Betting challenges have also been newly defined. These are structured tasks requiring players to bet on certain types of games or outcomes.
They may only be used if they do not implicitly encourage increased gambling volume. For instance, a challenge requiring a player to place bets on multiple game types to qualify for a reward could be in violation of the rules if it promotes higher gambling intensity.
Similarly, if the challenge includes elements of chance, such as needing to trigger a bonus round, it will be classified under “extra winning chances” and treated as a promotional tool with associated restrictions.
DGA seeks more clarity on promo terms
The duty of clarity in promotional communications has also been reinforced.
All material terms and conditions, such as wagering requirements, eligibility restrictions, and time limits, must be disclosed in close proximity to the promotional offer.
Importantly, operators may no longer rely on vague references to terms and conditions via hyperlinks.
If space is limited (e.g. in SMS or small banner ads), the most critical terms must still be disclosed, and all further terms must be accessible within one click. This requirement aims to alleviate consumer confusion and ensure promotional transparency.
In addition, the use of the word “free” in promotions is restricted. If any conditions, such as a deposit or a wagering requirement, are attached to an offer, operators cannot advertise it as “free,” “gratis,” “kvit og frit,” or similar.
The intent is to align consumer expectations with the actual terms being offered and to prevent misleading impressions of no-cost opportunities.
Finally, the amendments also delineate rules on how promotional offers are distributed. Promotions must not be targeted at too narrow a group of users; as a rule of thumb, the guidelines suggest they should be available to at least 100 consumers.
Lastly, offers cannot target players solely because they have not recently deposited or played, as this could create potentially exploitative incentives.
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