Navigating Platform Policies #3: Google & Apple

Welcome back to our third and final (at least for now) edition 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 examined the advertising policies of three of the largest social media companies, namely Meta, X, and TikTok. This week, we’re shifting our focus to Google and Apple, which, in addition to advertising, can also serve as platforms for hosting gambling apps for download. 

Google (& YouTube)

YouTube’s Illegal or Regulated Goods or Services Policies state that an advertiser cannot post content on YouTube if it aims to directly sell, link to, or facilitate access to online gambling or sports betting sites if the website has not been reviewed by YouTube or has not been certified by Google Ads.1  

To have the gambling site reviewed by YouTube, an advertiser needs to submit the full domain of the gambling site, the country or region that licensed the gambling website, a copy of the state-issued gambling license, and the date the gambling license was obtained.2 

To have a website certified by Google Ads, an advertiser needs to submit the company name, the domain of the website, the nature of the gambling website (for example, daily fantasy sports, sports betting, or online casino), and the jurisdiction of the license.3 Advertisers looking to advertise using Google Ads outside of YouTube also need to follow this certification process.4 Google allows the following types of gambling ads: 

• Social casino games where there is no opportunity to win anything of value such as money or prizes;  

• Physical, real money gambling activity or establishments, for example, brick-and-mortar casinos or streaming offline poker tournaments 

• Online, real money gambling – for example, online casinos or bookmakers, bingo or slots sites or apps, online ticket or scratch card purchases, online sports betting, games played with virtual currencies or items that have real-world value; 

• Online non-casino games – any internet-based game where money or other items of value are paid or wagered in exchange for the opportunity to win real money or prizes based on the outcome of the game, for example, fantasy sports, online chess tournaments, or “match-three” video games played for money or prizes. 

However, Google has country-specific requirements for jurisdictions that are permitted to advertise gambling products and services. For example, in Canada: 

• Online non-casino games: Google doesn’t allow advertising for internet-based games where money or other items of value are paid or wagered to win a greater sum of money or other item of value, except for Daily Fantasy Sports in certain provinces where legal; 

• Online gambling – Google allows ads promoting the following online gambling by province-licensed entities where legal: 

  • Sports betting; 

  • Online casinos. 

Google Play is the app store that serves phones and other devices that use the Android operating system. If a company wants to host a gambling app on the Google Play store, they must:5

• Successfully complete the application process;

• Ensure the app complies with all applicable laws and industry standards for each country in which it is distributed;

• Have a valid gambling license for each country or state/territory in which the app is distributed;

• Ensure that the product does not exceed the scope of its gambling license;

• Prevent under-age users from using the app;

• Prevent access and use from countries, states/territories, or other areas not covered by the gambling license;

• Ensure the app is NOT purchasable as a paid app on Google Play and does NOT utilize Google Play In-app Billing;

• Ensure the app is free to download and install from the Google Play store;

• Ensure the app is rated AO (Adult Only) or the equivalent; and

• Ensure the app listing clearly displays information about responsible gambling.

It’s important to note that the Google Store will only host the following types of online gambling products:

• Online Casino games;

• Sports Betting;

• Horse Racing (where regulated and licensed separately from Sports Betting);

• Lotteries; and,

• Daily Fantasy Sports.

Apple

If a company wants to create a gambling app available for download on the Apple Store, Apple’s App Review Guidelines states: 

Only include [gaming, gambling, and/or lotteries] if you’ve fully vetted your legal obligations everywhere you make your app available and are prepared for extra time during the review process. Some things to keep in mind:6 

• Sweepstakes and contests must be sponsored by the developer of the app; 

• Official rules for sweepstakes, contests, and raffles must be presented in the app and make clear that Apple is not a sponsor or involved in the activity in any manner;

• Apps may not use in-app purchases to purchase credit or currency for use in conjunction with real money gaming of any kind;

• Apps that offer real money gaming (eg, sports betting, poker, casino games, horse racing) or lotteries must have necessary licensing and permissions in the locations where the app is used, must be geo-restricted to those locations, and must be free on the App Store; 

• Illegal gambling aids, including card counters, are not permitted on the App Store; and, 

• Lottery apps must have consideration, chance, and a prize. 

The App Review Guidelines also state that apps that provide services in highly regulated fields (such as gambling) should be submitted by a legal entity that provides the services.7  

If a company is looking to advertise its’ website or app via Apple’s in-app advertising, Apple’s Advertising Policies8 state that Ad content for real money gambling and related services may be shown to adults only. Apple’s App Review Guidelines further state that:9 

2.5.18 Ads displayed in an app must be appropriate for the app’s age rating, allow the user to see all information used to target them for that ad (without requiring the user to leave the app), and may not engage in targeted or behavioural advertising based on sensitive user data such as health/medical data (e.g. from the HealthKit APIs), school and classroom data (e.g. from ClassKit), or from kids (e.g. from apps in the App Store’s Kids Category), etc. Interstitial ads or ads that interrupt or block the user experience must clearly indicate that they are an ad, must not manipulate or trick users into tapping into them, and must provide easily accessible and visible close/skip buttons large enough for people to easily dismiss the ad. Apps that contain ads must also include the ability for users to report any inappropriate or age-inappropriate ads. 

All of the above to say, related to in-app advertising, it should be permitted as long as the advertisements are only within 18+ Apps and: 

• Indicate they are an ad; 

• Do not manipulate users into tapping them; and

• Provide easily accessible “skip” buttons.