What AGCOM decided
On 29 July 2026, Italy's communications authority AGCOM adopted Delibera 200/26/CONS, a supplementary act to its 2019 guidelines on campaigns against gambling disorder. The text follows a consultation opened on 7 April 2026. Its central question is where legitimate responsible-gambling messaging ends and disguised advertising begins.
That line matters because Italy has banned gambling advertising since Article 9 of the Decreto Dignità (decree-law 87/2018). Separately, Legislative Decree 41/2024 obliges licensed operators to fund responsible-gambling communication. Per the summary by Lente Pubblica, concessionaires must spend 0.2% of net revenue annually on it, capped at €1 million per operator. The law therefore requires operators to speak about safe play while another law forbids them from promoting play. Prevention campaigns can become a loophole, and AGCOM says so in its recitals: responsible gambling must not become "a vehicle of surrogate advertising."
The strongest case for the rules
The regulator's argument deserves a fair hearing. A logo-heavy "play responsibly" spot with a famous face keeps a betting brand in front of viewers, and the ban exists to prevent exactly that. AGCOM also notes that online gambling has grown sharply since 2019. In its own words, sports betting, especially in real time, and online slots are categories of particular risk. If the prevention obligation is a marketing budget with a compliance label, the ad ban is hollow.
The guidelines respond with concrete limits. Per the Lente Pubblica summary, operator logos are allowed but must be subordinate to the prevention content: reduced in size, placed to the side, and not animated. Links to betting offers or bonuses are barred. Only links to strictly informative pages on player-protection tools qualify, and those must carry no promotional elements. Celebrity testimonials and influencers face tighter restrictions.
Where the target is right: illegal and pseudo-informational accounts
The most defensible part concerns social media. The delibera's recitals point to the visible spread of social accounts inviting people to gamble through avatars or physical tipsters, the cloning of legal sites, and the use of several platforms to reach players. AGCOM says it wants stronger direct action against illegal advertising on social networks. The Lente Pubblica summary adds that the Authority is concerned about accounts promising predictive ability or betting strategies, especially those steering users toward unauthorised operators. A link between this concern and ad-revenue-generating platforms comes from a trade-press report I could not verify, so treat it as unconfirmed.
Targeting unlicensed operators and fraudulent tipsters is proportionate. These actors face no licence conditions, no player-protection duties and no accountability. Enforcement against them protects consumers without restricting anyone's lawful speech.
Where the design is weaker
The operator-facing limits are harder to defend on evidence. AGCOM itself records a good argument from the consultation. Operator Diecimilauno argued that a national guidance act cannot add obligations or bans beyond those in primary law, and that limiting logo visibility could conflict with the concession convention of the customs and monopolies agency (ADM). That convention requires concessionaires to include their logo in anti-gambling-disorder actions. AGCOM's own recitals record that argument, and they add that a conflict between two public authorities' prescriptions could not be resolved by interpretation. AGCOM's reply, in the recitals I reviewed, rests on its enforcement powers under the Decreto Dignità.
There is also a policy tension. The delibera argues that responsible-gambling messages linking to a licensed operator's own protection tools help users tell legal gambling from illegal gambling. Illegal operators, it says, typically offer no responsible-gambling content or use only generic institutional links. Yet shrinking the licensed operator's brand in that messaging weakens the very signal AGCOM says consumers should use. If the brand is barely visible, players cannot see which operators are licensed and which are not.
A proportionate regime would put its enforcement effort where the harm concentrates: illegal advertising and unlicensed offers. It would keep the rules on legal operators simple and predictable. Vague tests such as whether a campaign's substance is genuinely preventive leave operators guessing, and they invite disputes over discretionary sanctions.
The DSA question
AGCOM is also Italy's Digital Services Coordinator. However, in the recitals I reviewed, the delibera cites Italian gambling and communications law plus the European Electronic Communications Code, not the Digital Services Act. I found no DSA reference in the sources I checked. Any enforcement against platforms hosting tipster content would presumably still run through the DSA's notice-and-action and illegal-content procedures, but the delibera does not say so, and I could not confirm that from the text. That silence is a gap: platforms and creators cannot tell which rules will govern removals, and speech-protective safeguards such as statements of reasons and appeals are DSA features, not guideline features.
A wider pattern
The guidelines arrive as Brussels moves further into youth-safety regulation. On 17 September 2026 the Commission set out a roadmap for an EU KIDS Act, with fines proposed at up to 6% of global sales. The instinct is similar: define a vulnerable group, then regulate the design of the channel. The design question is the same too. The best rules bind those who profit from harm, are written precisely, and can be tested against outcomes.
What to watch
- Whether operators challenge the logo and link limits as exceeding the primary legislation.
- Whether AGCOM publishes enforcement data on illegal social-media accounts, not only guidance.
- Whether any platform-facing action is anchored explicitly in the DSA.
AGCOM has identified a genuine loophole and a genuine illegal-market problem. The evidence supports concentrating on the second.