The Dutch government implemented a ban on ‘untargeted’ gambling advertisements in mid-2023 despite advertising being prohibited for individuals under 24 since 2013.
A recent study analysing Dutch gambling advertisements placed on Meta’s Facebook and Instagram Ad Library has revealed that a minority of adverts have potentially breached Dutch age-targeting regulations.
This finding emerged despite the tightening of regulatory controls and enhanced transparency measures introduced under the European Union’s Digital Services Act (DSA).
Conducted collaboratively by researchers from City University of Hong Kong and the University of Bristol, the study examined 277 paid adverts by licensed Dutch gambling operators displayed on Meta platforms between 2024 and early 2025.
Utilising the DSA-mandated Ad Library repository, which requires disclosure of age ranges specified by advertisers alongside the estimated user reach within broad age brackets, the research aimed to assess compliance with Dutch gambling advertising laws.
The study focused exclusively on Meta’s Ad Library data and licensed Dutch operators, thus excluding adverts on other prominent platforms such as TikTok, YouTube and Google, as well as unlicensed overseas operators whose presence in the Dutch market is significant.
Non-compliant advertisements
The study identified that 31 of the 277 adverts (11.2%) targeted age groups including those aged 18 to 23, a category particularly protected by Dutch law against gambling advertising. Any advertised age range incorporating one or more years within 18-23 was classified as non-compliant.
Compliance rates differed significantly between licence holders operating online and offline. Online gambling licence holders demonstrated a high compliance rate of 92.7% (only 7.3% non-compliant), whereas adverts linked to offline licence holders were less compliant, with nearly 30% (14 of 47 adverts) breaching age restrictions.
Several large operators were implicated in the breaches. For example, Holland Casino and associated brands ran adverts with age settings inclusive of under-24s. This resulted in substantial reach within this prohibited cohort.
Notably, one Holland Casino advert reportedly reached more than 21,000 Dutch users aged 18-24, with researchers estimating over 15% of its total Dutch reach likely being under 24.
Meta’s age-range reporting uses broad brackets (such as 18-24), which do not align precisely with Dutch law that restricts targeting specifically to 18-23-year-olds. This aggregation complicates exact compliance assessments.
95% of ad audience aged 24 or older
The Netherlands has maintained stringent gambling advertising controls since 2013 through the Decree on Gambling Recruitment, Advertising and Addiction Prevention, which prohibits advertising aimed at individuals under 24.
In 2022, it was announced that the Dutch government was to ban ‘untargeted’ gambling advertisements.
“Advertising is a means of directing people to the legal offer, but the importance of addiction prevention is more important,” said Franc Weerwind, minister for legal protection at the time.
“With this I want to protect vulnerable groups such as young people in particular.”
The amendment did not come into play until 2023, when it mandated online licence holders to employ best available measures to prevent targeting 18-23-year-olds. It also wished to demonstrate that at least 95% of the audience for ads are aged 24 or older.
The study applied these criteria to all adverts analysed. This included those by offline licence holders, identifying non-compliance via Meta’s disclosed targeting ranges.
Causes behind non-compliance
The researchers identified several factors contributing to breaches:
- Automated ad optimisation tools: Some operators used Meta’s “Advantage+” feature. This did not alert them to set the minimum legal age at 24 for Dutch audiences. Because defaults often start at 18, advertisers may inadvertently target prohibited age groups.
- Human error and inconsistent checks: Manual mistakes and uneven enforcement of pre-publication compliance procedures were evident among some operators.
- Platform data constraints: Limitations in Meta’s reporting make it difficult for advertisers and external monitors to conclusively verify compliance.
Notably, Meta’s age-range reporting uses broad brackets (such as 18-24), which do not align precisely with Dutch law that restricts targeting specifically to 18-23-year-olds.
Policy recommendations
The study offered practical recommendations to improve compliance and regulatory oversight.
- Social media platforms should provide reach data by single-year age increments and enable queries for arbitrary age ranges to allow precise compliance verification.
- Platforms ought to apply country-specific legal age minimums by default, such as automatically preventing Dutch gambling adverts from targeting users under 24.
- Dutch regulators should clarify the applicability of the Decree’s prohibitions to adverts placed by offline licence holders on social media; an investigation is reportedly under way after initial ambiguity.
- Regulatory authorities should leverage the transparency afforded by the DSA to prioritise enforcement, possibly requiring pre-authorisation or manual vetting of gambling advertisements.
The report comes with Meta under fire from Tim Miller, executive director of the UK Gambling Commission, for its illegal gambling ads.
“Anyone who spends time on their platforms will likely have seen ads appearing for illegal online casinos,” Miller said. “Most notably, and perhaps most worryingly, many aimed at GB users are for the so-called ‘not on GamStop’ sites.
“These are targeted at consumers that have taken the often difficult step to self-exclude from online gambling through the use of GamStop, Britain’s multi-operator self-exclusion scheme.”
