The overall impression of the marketing must be considered. What matters is the way the message is perceived by the consumers, not the way the advertiser/company intended for the message to be perceived. In general, the marketing also needs to be objective, balanced, reliable, true, and provable.
Specific information that must be apparent in the marketing:
- Age limit: The age limit required to gamble must be clearly stated (18+).
- Support organisation: Contact information to an organisation that provides information about and support in relation to gambling must be clearly stated. The organisation should be independent of the gambling business and be able to offer free help based on Swedish conditions. The Swedish Consumer Agency recommends “Stödlinjen”. Some form of supplementary information should be provided, such as telephone number, web address or e-mail address. This requirement does not apply to radio messages (though it still applies to podcasts).
- T&Cs apply: The terms and conditions relating to the specific bonus, tournament etc must be clearly accessible in all forms of promotional material, as well as the term “T&Cs apply”.
- Responsible Gambling message: For example, “Spela Ansvarsfullt” (Play Responsibly).
The marketing must be “moderate”. Below are some examples of what has been considered not moderate and other checks to make sure that the marketing is moderate:
- That marketing does not include claims that gaming can provide a solution to financial concerns, an alternative to employment, a way to earn a livelihood of financial security
EX: Statements such as ”Nämen du behöver ju inte jobba. Du kan ju bara spela (Well, you won’t have to work. You can just gamble)”, ”Jag tycker bara det är otroligt konstigt att du jobbar (I just think it’s incredibly strange that you work)” or ”Varför inte låta magen jobba för dig? På casinot (Why not let your stomach work for you? At the casino)”.
- That marketing does not contain pressuring messages such as ‘’you must’’, ‘’you have nothing to lose’’ or ‘’come now’’.
EX: Swedish Consumer Agency: Statements such as “Spela nu (Play now)”, ”Spela direkt (Play immediately/directly)”, ”Satsa nu (Bet now)”, ”Pröva lyckan (Try your luck)”, ”Börja spela (Start playing)”, ”Du lär ju testa (You should try)”, ”Prova nu! (Try now!)” are considered pressuring messages.
However, statements such as ”Läs mer (Read more)” and ”Till Registrering (To Registration)” have been deemed OK.
Statements such as ”Det här kan nog vara din chans att vinna stort! Är du redo?! (This may be your chance to win big! Are you ready?!)”, ”Testa lyckan i vårt casino! (Test your luck in our casino!)” and ”Missa inte allt det här, Missa inte din bonus för nya spelare (Don’t miss all this, do not miss your bonus for new players)” are also considered to be pressuring messages.
- That the marketing is not intrusive or intended to attract particular attention.
EX: Pop-up and take-over advertisements that the consumer cannot fend off and that cover the entire screen of the website that the consumer wants to access.
Statements like “Söker du spänning? (Are you looking for excitement?)” followed by the button “Ja för tusan (Hell yes)” and “HALLÅ!?! NYTT CASINO! (HELLO!?! NEW CASINO!)” follow by the button “Du lär ju testa! (you will want to test!)” are also considered to be intended to attract particular attention.
- That the marketing does not contain claims of quick payments. Even if the information is correct, it still has to meet the moderation requirement.
EX: ”UTTAG INOM 5 MINUTER (WITHDRAWALS WITHIN 5 MINUTES)”, ”Snabbare utbetalningar! (Faster withdrawals!)”, ”Blixtsnabba uttag (Lightning fast withdrawals)”, ”Fria uttag och pengar på kontot inom 5 minuter (Free withdrawals and money in the account within 5 minutes)”.
- That marketing does not contain claims that gaming can provide a solution to social, personal or professional issues.
- That marketing does not portray gaming as necessary, or as a priority in lifeg. ahead of family, friends, education or professional commitments.
- That marketing does not portray gaming as a path to social success, for example by using well-known individuals with suggestions that gaming has contributed to their success.
- That marketing does not contain claims that gaming itself entails – or can enhance – positive personal qualities, e.g. that gaming can improve consumers’ self-esteem, self-respect or result in recognition or admiration.
- That marketing does not represent gaming in a context that links gaming with strength or irresponsibility.
- That marketing does not convey degrading views of moderate gaming.
- That marketing does not promote gaming behaviors where consumers lie about their gaming.
- That marketing does not promote gaming behaviors where consumers borrow money to gamble.
- That marketing does not promote gaming behaviors where a consumer thinks more about gaming than what the consumer really wants.
- That marketing does not advocate for or encourage consumers to chase past financial losses.
- That marketing does not advocate for or encourage consumers to chase past financial losses.
- That marketing does not encourage gaming with money that consumers cannot spare.
- That marketing does not encourage or promote criminal or asocial behavior.
- That marketing does not play on stereotypical notions of male and female.
The marketing must be reliable and not misleading. Below follow some examples of what has been considered misleading information and checks when making sure the marketing is not misleading:
- That marketing is not designed in a way that misleads the consumers.
EX: Information about bonuses must be correct. Information indicating several bonuses are available has also been considered misleading, since the SGA’s bonus rules don’t allow it.
- That marketing is never designed to suggest or indicate that gaming is risk-free, or that there are products that cannot lead to problem gambling.
- That marketing does not contain false information about the size of the winnings.
- That marketing of previous winners or winnings is not incorrect or false.
EX: Stories about previous winners must be correct.
- That marketing does not exaggerate the chances of winning or suggest that a player is guaranteed to win.
EX: “Jag hann inte ens blinka.. (I didn’t even have time to blink..)”, “Det sa bara swoosh! (It just said swoosh!)”, ”Jackpottarna bara stiger och stiger. Casinot söker med ljus och lykta efter svensk vinnare, kolla och ta chansen! (The jackpots only rise and rise. The casino is looking for a Swedish winner, check it out and take the chance!)”
- That marketing does not contain claims or suggestions that the outcome of a draw in a game of luck is dependent on or can be affected by anything other than chance.
EX: “ Så utnyttjade de tekniken för att vinna storvinsterna.. (They used their skill to win the jackpot ..)”
- That marketing does not portray the game to be a quick/faster path to winning.
EX: “Vann supervinst – pengar på kontot på 7 minuter (Won the super jackpot – money in the account in 7 minutes)”
- That any conditions for participating in a marketing activity or for accessing offers (including supplementary benefits) are clear and accessible to the consumer in a manner appropriate to the distribution and marketing channel, allowing the consumer to make an informed decision about his/her gaming.
- That information on each type of gaming product and game is provided in terms of win frequency and/or prize plan, if applicable to the product, and the share of bets that is paid to players in the form of winnings (RTP share).
- That the sender is clearly identifiable in all marketing. This also means that clear marketing labeling must be part of collaborations with influencers and bloggers and when purchasing editorial content, unless otherwise stated in applicable legislation, such as the Radio and TV Act.
- That it is not suggested by the marketing that it is possible to gamble anonymously or without registration for games that require registration under the Gambling Act.
- That the marketing cannot be confused with advertising for gaming companies/brands that do not have a gaming license.
- That the marketing does not encourage exaggerated gambling.
EX: “The more you play the more you win …”, “She lost hundreds but continued and became a millionaire..”, ”Från pank till 122 000 kronor på några timmar (From broke to SEK 122 000 in a few hours)”, ”Marias intuition gav resultat. Hon förlorade hundralappar men fortsatte (Maria’s intuition yielded results. She lost hundreds but continued)”
- That the marketing is not addressed to – or designed to appeal specifically to – persons under the age of 18. This rule also applies to “marketing which by its design allows it to be assumed that children and adolescents especially notice and can be affected by it”. The overall impression is decisive.
- That the marketing is not otherwise unclear, incomprehensible, ambiguous or inappropriate.
- Information about bonuses must be correct. Information indicating several bonuses are available has also been considered misleading, since the SGA:s bonus rules don’t allow it.
- Clear reference to conditions of bonus. The reference should, as a rule, mean that the consumer can access the conditions with no more than one click of the button. The information should also not be embedded in long and linguistically inaccessible texts. The reference should also not be difficult to read due to text size, colour scheme or placement.
Illegal and unwanted sites
- Gaming company logotypes must not appear on sites that are illegal, such as illegal streaming sites, or on sites that otherwise contribute to an image of the gaming industry that we do not want to be associated with, such as pornography.