Jack Tadman

Navigating Platform Policies #2: Meta, X, & TikTok

Welcome back to our second installment of Navigating Platform Policies, the blog series where we look at social media advertising policies and the considerations for brands who want to advertise gambling content on those platforms. 

 

In the last update, we covered the policies of major streaming platforms Twitch and Kick. This week we’re taking a deep dive into the policies for the Holy Trinity of social media giants – Meta (of Facebook and Instagram), X (formerly Twitter), and TikTok.

 

Meta (Facebook & Instagram)

 

As it relates to streaming, Meta’s Gaming policies specifically prohibit real money gambling which is defined as “content that attempts to sell or promote online gaming and gambling services where anything of monetary value (including cash or digital/virtual currencies, ex: bitcoin) is required to play and anything of monetary value forms part of the prize”.1

 

Regarding advertising, Meta’s Online Gambling and Games advertising policy2 states that to promote online gambling and games, advertisers will need to request written permission from Meta using an application form.3 The following types of companies require the advertiser to fill out the application form:4 

 

  • All forms of online gambling, such as betting, lotteries, raffles, casino games, fantasy sports, bingo, poker, skill game tournaments and sweepstakes.

  • Games where anything of monetary value is included as part of a method of entry and anything of monetary value is included as part of the prize, including but not limited to cash or digital currencies like Bitcoin. This includes games that require purchases to continue gameplay or provide an advantage in winning prizes in cases where the prize is of monetary value.

  • Ads with destination (landing) pages that contain promotions for online gambling or games, even if there is no opportunity to gamble or game directly on that page, such as aggregator or affiliate sites.

  • Games offering a limited trial period and requiring payment thereafter. 

 

The application process requires you to provide the following information to Meta: 

 

  • The corporate account the ad will run from; 

  • The URL/app the advertiser wants to advertise and the target territory 

  • The type of gambling/games that the advertiser wants to advertise

  • Documentation (a gambling license or a reasoned legal memo by a law firm) that substantiates the advertiser’s ability to lawfully advertise the product/service; and

  • Any protective measures that the product/service has (for example, geo-blocking, age-gating, KYC checks). 

 

Authorized advertisers must follow all applicable laws, including targeting their ads in compliance with the minimum legal age at which individuals may use and be targeted with content relating to the advertised activity in the applicable territory. At a minimum, ads may not be targeted to people under the age of 18. Further, ads for online gambling and games may only target the following countries (and prior written permission must be obtained for each territory/sub-territory): Australia, Austria, Brazil, Canada, Columbia, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, India, Ireland, Japan, Kenya, Mexico, Netherlands, Nigeria, Norway, Peru, Poland, Portugal, Romania, Serbia, Slovakia, South Africa, Spain, Sweden, Switzerland, Turkey, United Kingdom, and the United States.5 

 

Despite the above restrictions, advertisers can run ads for social casino games and free-to-play games without prior written permission from Meta as long as they: 

 

  • Don’t offer the opportunity to win money, coins, gifts, or anything of value;

  • Don’t target people under the age of 18.

 

X

 

X’s ad content policies prohibit the promotion of gambling content, except for campaigns targeting regulated jurisdictions.6 The policy applies, but is not limited to: 

 

  • Online casinos and gambling, sports betting, and bingo; 

  • Physical, brick-and-mortar casino establishments; 

  • Online fantasy sports sites; 

  • Bonus codes, vouchers, and coupons redeemable for gambling content; 

  • E-books or websites facilitating or leading to online gambling-related content, including affiliates and other sites driving traffic to gambling; 

  • Gambling-related software, such as gambling software and poker odds calculators

  • Sites or services providing tips, odds, handicapping, sports picks, forecasts, or poker odds calculators; 

  • Scratch games; 

  • Lotteries; and, 

  • Games or apps played for money. 

 

The policy does not prohibit: 

 

  • Hotels with a casino, where the focus is on the hotel; 

  • Gambling accessories, such as poker chips or pachinko machines; or, 

  • News and information about fantasy sports. 

 

For regulated jurisdictions, the advertiser needs to apply for X Ads Pre-Authorization,7 where the advertiser would need to submit to X: 

 

  • Valid licenses, permits, or certifications to advertise the product type or service type in the applicable jurisdiction; 

  • The URL of the content they wish to advertise; 

  • The countries where the advertiser intends to display the advertisements. 

 

For Canada, the following ads are permitted subject to obtaining pre-authorization from X:

 

  • Brick-and-mortar casino, poker, bingo, sports betting, and horse racing ads; 

  • Lottery and sweepstakes ad;

  • Fantasy sports ads;

  • Games are free to play but result in the payment of money or a prize of value; and, 

  • Affiliates and aggregators.

 

TikTok

 

TikTok has the strictest policy out of all the platforms covered in this blog. TikTok’s Advertising Policy states:8

 

We do not allow ad content and landing pages to sell, solicit, or facilitate access to casinos or gambling activities, either on online websites or in physical establishments, where money is cashed in or cashed out.  The following are examples of what is not allowed:

 

  • Free credits, vouchers, and coupons, in any form, including printed or digital codes, for use in casinos or gambling games;

  • Websites, software, products, or services that facilitate or drive traffic to casinos and gambling games or their related content, including odds calculators, tips and tricks, rules and strategies, hot picks, or forecasts;

  • Games of luck or chance, such as scratch-off games, bingo, or any similar games or apps that could result in monetary or valuable prize gain;

  • Tools, instruments, devices, props, or any other accessories or supplies for use in casinos or gambling games, such as tutorials, e-books, or poker calculator software.

 

TikTok’s Advertising Policies also include country-specific rules. For example, in Canada, the Advertising Policies state: 

 

  • Offline and online gambling (casinos, lotteries, and sports betting) may be allowed if the advertiser: 

    • works with a TikTok sales representative to determine eligibility, 

    • obtains TikTok’s permission to run ads, and 

    • complies with all applicable laws and regulations; 

  • Fantasy sports, daily fantasy sports, and reward gaming may be allowed if the advertiser works with a TikTok sales representative to determine eligibility and complies with applicable laws and regulations; 

  • Sweepstakes may be allowed if the ad only targets users aged 18 years and older and the games are free to play (in-app purchases are allowed); and, 

  • Social casino games may be allowed if the ad is restricted to users aged 18 years and older, the advertiser works with a TikTok Sales Representative to determine eligibility, the advertiser does not make direct comparisons to real money gambling, it’s clear that the presentation of the ad that the user cannot win real money, games must be free to play, and purchases are allowed if there are no money-out options.

 

Final Thoughts

 

Whether you are thinking of developing a new gambling product or service from scratch or are looking to expand your company’s advertising presence on social media, it’s always important to keep in mind the terms and conditions and gambling policies of the specific platform you are thinking of advertising on. We regularly help clients advertise on their social media platform of choice by providing legal opinions on the legal landscape of their product/service, feedback on whether marketing content complies with local laws, and assistance with disputes if platforms flag our client’s content. 

 

This is the second part of our new series looking at gambling policies of major social media platforms. Follow us on LinkedIn and watch out for our next installment where we’ll be covering Google and Apple, as well as the policies related to hosting a gambling app on their platforms! If you missed the first part of the series you can find it here. And, if your company requires a legal opinion about your product or service, or you are looking to advertise your company on social media and have questions, please don’t hesitate to reach out to GME Law. 

1 Meta Business Help Center, Facebook Gaming policies.

2 Meta Business Help Center, About Meta’s Online Gambling and Games advertising policy.

3 MFacebook, Online Gambling & Games Advertising – Application Form.

4 Meta Transparency Center, Advertising Standards, Online Gambling and Games.

5 Ibid.

6 X Business, Ads Content Policies, Gambling Content.

7 X Ads, Apply for Ads Pre-Authorization.

8 TikTok Business Help Center, Gambling and Games, last updated: August 2024.

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