Working with gambling streamers and creators: due diligence

Before you sign a gambling streamer or content creator, check four things: that the platform allows your product to be promoted there, that the creator's audience passes the UK under-18 tests, that every piece of content will be labelled as an ad, and that the audience is real. In the UK you carry the risk for all four. The ASA has said gambling operators are primarily responsible for CAP Code compliance and can be held wholly or jointly responsible for their affiliates' marketing.

Platform policies and UK rules below were read on 4 October 2026. Platforms change their rules often, so check again before each campaign.

What each platform allows

Twitch

Twitch's Community Guidelines say: "We do not allow users to share links or affiliate codes to sites that contain slots, roulette, or dice games." That applies to any such site, licensed or not. Separately, Twitch names six sites that cannot be streamed at all: stake.com, rollbit.com, duelbits.com, roobet.com, blaze.com and gamdom.com, "or associated domains", and says it may identify others. Logos of listed sites on screen or in a bio count the same as links. Free or social versions of those sites are also banned, as is skins gambling.

Sports betting, fantasy sports and poker are permitted "at this time". Twitch's Branded Content Guidelines still list "Risky Gambling Products, such as promoting online slots or roulette websites" as prohibited branded content. Any branded content must use Twitch's disclosure tool, enforced since 1 July 2023, and Twitch says that tool will not always meet legal disclosure duties. Streams featuring live gambling need the "Gambling" Content Classification Label.

Kick

Kick's Community Guidelines (updated 19 March 2026, Guideline 11) allow affiliate links and sponsored gambling content if the creator follows local law, and "Sponsored gambling is permitted only for platforms holding valid licenses in the relevant jurisdiction". Affiliate links must be disclosed clearly, near the link or audibly on stream. Gambling with funds provided by other users is prohibited, and minors may not take part. Paid partnerships must use Kick's Branded Content tool plus an overlay and a spoken disclosure.

YouTube

Since 19 March 2025 YouTube has not allowed any method of directing viewers to gambling sites or apps not certified by Google, including links, logos and verbal references. From 17 November 2025 that covers gambling with skins, cosmetics and NFTs, and social casino content is age-restricted. Content that depicts or promotes online gambling, including from certified sites, may be age-restricted. Promising guaranteed returns is not allowed even for certified sites. Paid promotions must be declared with the paid promotion box.

Instagram and Facebook

Meta requires written permission from Facebook for both the business partner and the creator before branded content promotes real-money gambling. Posts must be targeted to people aged 18 or over, restricted to the jurisdiction the permission covers, and published with the paid partnership label.

TikTok

TikTok's Branded Content Policy (version effective 31 August 2026) restricts gambling branded content in the UK to users over 18 and to the market where it was posted. In other markets, including Ireland, Italy, the Netherlands, Belgium, Poland and Portugal, it is not allowed at all. The commercial content disclosure toggle must be on.

X

X's Paid Partnerships Policy lists gambling, including sports betting, lotteries and social casinos, as a prohibited industry for organic paid partnerships in the UK, the EU and Australia, with exceptions considered case by case. X's separate gambling ads policy allows paid ads targeting the UK only from advertisers licensed by the Gambling Commission, with pre-approval.

Operator view

A creator who is willing to break a platform rule for you is also willing to break one against you. If the brief only works by ignoring the platform's policy, the brief is wrong.

UK advertising rules for creator content

CAP and ASA rules apply across the UK. These are the ones that decide most creator deals.

Strong appeal: 16.3.12

Under CAP Code rule 16.3.12, gambling ads must not be likely to be of strong appeal to under-18s, especially by reflecting or being associated with youth culture, and must not include a person or character with strong appeal to under-18s. The "strong appeal" test replaced the older "particular appeal" test on 1 October 2022.

CAP's under-18s gambling guidance (current edition dated October 2025) gives a rule of thumb: at least 100,000 social media follower accounts registered to under-18s, across platforms, indicates strong appeal. Look at the absolute number, not just the share, and check every major platform the creator uses. The guidance warns that the true under-18 figure is likely to be significantly higher than registered ages show, because many under-18s register with an adult age. It names anyone with a significant under-18 social following, and leading eSports players, as high risk.

The BetUK ruling (13 March 2024) shows how this works. A radio ad featuring former footballer Adebayo Akinfenwa was upheld because at least 157,000 under-18 followers were identified, although they were only 8% of his Instagram following and 13% of his Snapchat following.

Media and age: 16.3.13 and 16.3.14

Rule 16.3.13 says gambling ads must not be directed at under-18s through the media or context they appear in. In one-to-many media, CAP's 2021 guidance says age-restricted ads must not go where under-18s are likely to be more than 25% of the audience. For influencer content, you must be able to show the ASA, mainly from the audience data you hold, that under-18s are unlikely to exceed 25%. A paid post is judged on that account's followers.

Rule 16.3.14 bars anyone who is, or seems to be, under 25 from gambling or playing a significant role. In the Midnite ruling (16 September 2026) an affiliate's paid TikTok ad used an AI-generated character who looked under 25. Midnite said it had not sanctioned the ad. The ruling was made against Midnite and the affiliate anyway.

Which data counts

CAP accepts signed-in user data where you can satisfy the ASA it reflects the wider audience, and data from a creator's other platforms may be relevant. Where non-logged-in users can watch, the audience is likely to be wider than signed-in data shows. In the White Hat ruling (16 September 2026) the ASA rejected referral data as audience evidence, because every successful referral is 18+ by definition, and decided on content and context instead. The strong appeal rules do not apply only where you can robustly age-verify every recipient as 18+. Self-declared platform ages are not enough.

Labelling

Ads must be obviously identifiable. The ASA recommends "#ad" and advises against "sponsored", which it calls open to varied interpretation. "Affiliate" alone is not well understood. Kick's own examples include "#Sponsored", so tell UK creators to use "#ad". The ASA's definition of influencer includes streamers and names Twitch and YouTube.

Your licence

In Great Britain, the Gambling Commission says licensees are responsible for the third parties they contract with (LCCP 1.1.2 and 1.1.3) and must carry out due diligence and keep oversight. Failure can lead to regulatory action, including suspension or loss of the licence.

This is a summary, not legal advice. Read CAP's under-18s gambling guidance and the Gambling Commission's third-party page in full.

Funded balances and disclosure

If a deal gives the creator a balance to play with, disclose it. The Gambling Commission's research with teenage boys and young men (11 December 2025) quotes participants saying companies "give them money to play with", and found that knowing this rarely reduced gambling's appeal. The young people interviewed already assumed it, so hiding it protects nobody.

We have not verified a UK rule written specifically about funded balances, so we do not cite one. The ad must still be obviously identifiable as an ad. Put the funding in the contract, require it to be stated on stream, and keep a record of what you credited.

Affiliate view

A creator can easily hear "house money" as a perk. For the operator it is a disclosure obligation. Agree the on-stream wording before the first stream, not after a complaint.

Botted audiences

Twitch, Kick and YouTube all ban inflating viewer or follower numbers. YouTube's ban covers viewbotting by someone the creator hired. Twitch says it does not penalise good-faith streamers viewbotted by a third party.

Streams Charts and Audiencly reported, as covered by Tubefilter, that in Q2 2025 more than 41,000 Twitch channels averaging 50+ viewers had at least one suspicious stream and about 4,400 showed consistent signs of viewbotting, more than 16% of comparable Kick channels were suspected, and "Virtual Casino" was the most affected category at 13%.

No regulator or platform publishes a threshold that proves botting. Look for signals, and weigh them together:

• A high share of logged-out viewers (a signal Streams Charts uses)
• Viewer lines that are flat or regimented rather than shaped by the stream
• Few active chatters against the viewer count. Kick added an active chatter count in August 2026. Many real viewers lurk, so this alone proves nothing
• Unexplained jumps in followers or viewers
• Whether the creator will connect their account to share data directly

Streams Charts notes that modern bots rotate IP addresses and simulate chat, so no single signal is enough.

What each platform's data can show you

YouTube's age13-17 band includes viewers YouTube estimates to be under 18, but it is withheld where data falls below unpublished thresholds. YouTube's developer policies (updated 14 September 2026) forbid creating new or derived metrics from API data and aggregating it across content owners, require a check every 30 days that consent still stands, and require deletion within 7 days of revocation.

So for Twitch and Kick you cannot evidence the 25% test from platform data. Ask for the creator's other platforms, judge the content and themes, and record your reasoning.

Due-diligence checklist

1. Confirm the platform allows your product, in that market, and that you are not on Twitch's list.
2. Confirm your licence covers the market the creator's audience is in.
3. Collect under-18 data from every major platform the creator uses and total the absolute numbers.
4. Check the content for youth themes and anyone who is or looks under 25.
5. Agree "#ad", the platform's disclosure tool and a spoken disclosure in the contract.
6. Write funded balances into the contract, with on-stream disclosure.
7. Review audience signals and keep the evidence.
8. Use a unique promo code or tracking link per creator, where the platform allows them.
9. Monitor live content, keep recordings, and set an exit clause for breaches.
10. Recheck platform rules before each campaign.