Marketing: Can we advertise?

Online Gaming MarketingThe Hellenic Gaming Commission has regulatory oversight for gambling advertisements. Only licensed operators are permitted to advertise gambling products or services. The advertising of unlicensed gambling products can be sanctioned via a minimum two-year prison sentence and a fine of up to EUR 200,000. Forthcoming reform (announced):The regulator has publicly indicated that a new legislative package planned for 2026 will introduce enhanced powers to immediately suspend or prohibit advertising for illegal gambling services, including action against affiliates, media outlets, influencers and advertising networks that promote unlicensed operators. This would mark a shift from reliance on post-factum criminal sanctions to faster administrative intervention. Law 4002/2011 contains restrictions put in place on the advertising or marketing of gambling products to consumers located in Greece. Prominently, Article 35 dictates that all forms of advertising must feature information concerning player age restrictions and the prohibition of self-excluded players from gambling. Article 35 also requires advertisements to feature the names and contact information of organisations which provide support and treatment to persons which suffer from problem gambling. The former Regulation on Commercial Communications (Decision No, 163/4C/2015, as amended by Decision No. 184/3/2015) was repealed by Article 13 of Decision No. 79292/2020. Article 8.3 of Decision No. 79292/2020 amongst other things prohibits gambling advertisements from: Adopting unfair commercial practices, such as containing misleading information or omitting information with the intention to mislead. Taking advantage of a lack of general knowledge on the part of consumers in relation to the chances of them winning. Giving the impression that the outcome of any gambling games played can be controlled or influenced through the use of superstitions, or that such superstitions can lead to positive outcomes. Implying that the skills of a player or the frequency at which they play can have an effect on the player’s chance of winning. Suggesting gambling can enhance a consumer’s personal qualities or be used as a way to obtain recognition or admiration from others. Recently, Greece has adopted Decision No. 79292/2020 into the gambling industry’s regulatory framework. This decision has imposed an obligation on operators to secure approval from the regulator for all gambling advertisements before publication, as well as banning gambling advertisements on the internet “either in the form of a pop-up window, such as pop-up, pop-under, overlays, or in any other form that restricts and/or obstructs browsing. Decision No. 79292/2020 is also comprehensive in setting out advertising restrictions designed to protect minors (in Greece, those aged under 21). In particular, commercial communications are prohibited from: Referring to or containing elements of minors’ mentality, habits and behaviour and/or use of phrases identified as being prevalent in the vernacular of minors. Presenting gambling as an activity which marks transition from adolescence to adulthood. Featuring real or fictional characters which are or seem to be under the age (21) at which participation in gambling is permissible. Being displayed before, during or right after the conducting or broadcasting of youth sporting events. Being displayed before, during or right after a radio / television programme targeted at minors. ## Demo games (play for fun): HGC Instruction 1/2026 HGC Instruction 1/2026 (HGC Decision 32/4/22.07.2026, Government Gazette B’ 4900/05.08.2026) implements paragraph 8.12 of Decision No. 79292/2020 and sets binding rules for demo or “play for fun” games offered online by licensed operators. The display and provision of a demo game by the operator is itself a commercial communication and is governed by Decision No. 79292/2020. Under the Instruction: a demo must be an accurate simulation of an HGC-certified game, must not involve any financial risk and must not allow real winnings or any other prize or reward, including entries for use in gambling; demos may be promoted only within the operator’s online gaming environment and may be played only after the player has logged into their player account; any third party, including affiliates, is prohibited from displaying or otherwise presenting demo games; each demo must follow the corresponding real-money game as to symbols and graphics, participation limits (max bet, max win), the prize distribution system, the paytable in force at any given time and the game guide information; a player’s total time on demo games may not exceed 20 minutes per calendar day; and the operator must notify the HGC of the demo games it intends to offer. Breaches are subject to administrative measures and sanctions under Ministerial Decision 125944/2020 (Government Gazette B’ 4884/2020). The Instruction formally applies from 1 September 2026. In September 2026 the HGC informally confirmed that the implementation deadline has been extended to 31 December 2026. The extension has not been published and, according to the HGC, was communicated only to licensed B2C operators. Although the Instruction is addressed to licensed B2C operators, it affects B2B game suppliers and platform providers in practice. Suppliers must keep demo and real-money versions aligned, and the safer reading is that playable demos should not be made available to users in Greece outside the operator’s logged-in environment, including through suppliers’ own websites or public demo libraries. Affiliate marketing has been recently regulated. Affiliates are subject to their own licence (Affiliate Suitability Licence) – Minimum requirements and low cost EUR 1.000 – one-off approval fee. Licence holders must ensure that commercial communication through affiliates follows the same terms, restrictions and safeguards that apply to the licence holder. Affiliates may not carry out the operator’s commercial communication directly with players or the public, for example through newsletters or RSS feeds (Part 5, HGC Directive 4/2021). Advertising service providers and affiliates may not provide services to illegal gambling operators (Article 11.2, Decision No. 79292/2020). Part 8 of HGC Directive 4/2021 distinguishes sponsorship from product placement and corporate social responsibility. It limits sponsored announcements to identity-type messages that are not linked to services, purchases, benefits or offers, and requires the +21 age limit to be shown with the brand in all sponsorship actions. Jerseys of sponsored teams are exempt, but individual athletes’ outfits and artistic outfits are not. Outdoor advertising must be located at least 200 metres from primary and secondary schools and boarding houses (Article 3.9, Decision No. 79292/2020). Commercial announcements may not promote bonuses, gifts, benefits or discounts linked to the cost of participation, except within loyalty programmes under Article 8.6 (Article 8.5, Decision No. 79292/2020). Advertising is overseen by the HGC under the Regulation on Commercial Communication (MD 79292/2020). Only licensed operators may advertise. Marketing must reference prohibitions for minors and self-excluded persons, include addiction-helpline information, avoid glamorising gambling or implying financial success, and must not promote credit for gambling. Advertising of unlicensed products is criminally sanctioned (minimum two-year prison sentence plus fines up to EUR 200,000). The NCRTV monitors broadcast gambling advertising.