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On October 9, 2025, the Canadian Gaming Association (CGA) published their Code for Responsible Gaming Advertising (the CGA Code)1, set to take effect on January 1, 2026. The CGA Code marks a new industry standard and provides a comprehensive framework designed to promote socially responsible advertising practices across Canada's gaming sector.
Background
The CGA is a national trade association representing leading operators and suppliers across the gaming, sports betting, eSports, and lottery industries. Developed in collaboration with stakeholders in the gaming industry, the CGA Code is administered by Ad Standards, Canada's national self-regulatory body for advertising.
The CGA Code aims to align advertising practices with existing federal and provincial regulations, enhancing clarity, transparency, and consistency across the gaming sector. The CGA Code is a voluntary commitment by the gaming industry and is intended to complement current legal and regulatory obligations, including broadcasting codes and the Canadian Code of Advertising Standards (Canadian Code).2 The CGA Code serves to strengthen the existing framework by offering more targeted guidance and specificity around responsible advertising in the gaming industry.
Ultimately, the CGA Code is not intended to replace existing marketing and advertising standards, such as those established by the Alcohol and Gaming Commission of Ontario (AGCO) following the legalization of iGaming in April 2022, but rather to complement and support these regulatory frameworks.
Application and Scope
The CGA Code applies broadly to all forms of gambling, gaming, or betting advertising, in any form communicated to Canadians including digital, print, broadcast, and out-of-home advertising, by CGA members or other signatories to the CGA Code.3 The CGA Code does not apply to promotional content related to the non-gaming aspects of these businesses, such as restaurants and entertainment venues located within land-based casinos.4
Certain types of content and media are explicitly excluded from the definition of "advertising" under the CGA Code,5 such as:
- lottery products offered by provincial lottery corporations;
- corporate communications, such as press releases, annual reports, and corporate reports; and
- packaging, wrappers, and labels.
Additionally, the CGA Code also excludes foreign broadcast media where the advertising originates from foreign signals, so long as the advertisement does not intentionally target Canadian audiences.6
CGA Code Core Principles
The CGA Code is structured around the following five core principles:
1. Truthful and Transparent Advertising
Gaming advertising must be built on transparency and provide clear and factual information about the gaming product.7
This includes requirements that gaming advertising must not misrepresent gaming experiences or the likelihood of winning (e.g., falsely suggesting that "everyone is a winner"),8 and must prominently disclose all material conditions for participation, such as deposit requirements or number of plays required to win.9
2. Social Responsibility and Good Taste
Gaming advertising must portray gambling in a responsible manner, depict moderate play, and reflect contemporary standards of good taste.10
This includes the requirement that gaming advertising must not depict individuals gambling excessively or prioritizing gaming over personal responsibilities such as their work or families. For example, an advertisement depicting someone leaving a dinner table or missing a parent-teacher meeting to place a bet would not comply with the CGA Code.11 Additionally, advertisements cannot use imperative language to encourage immediate gambling (e.g., "Hurry! Bet Now!"),12 and must avoid any association with alcohol, drugs, or other intoxicating substances.13
3. Adult Audience
A fundamental requirement of the CGA Code is ensuring that gaming-related advertisements are directed exclusively to individuals who are of legal age to participate in gambling activities (which, depending on the province and the type of activity, is usually 18 or 19 years old). Advertisements must not be designed, presented, or distributed in a manner that appeals to individuals below the legal gambling age.14
This includes the prohibition on the use of cartoon characters, fairy tale figures (e.g., Santa Claus and the Tooth Fairy), or jingles that resonate with children.15 Gaming-related advertisements must feature individuals who are at least 25 years old, (with documentation to verify age), and who actually appear to be above the legal gambling age.16 Additionally, advertisements must not include professional or amateur athletes who are recognizable or commonly known, unless the athlete is unidentifiable or the advertisement is exclusively for the purpose of promoting responsible gambling.17
4. Responsible Gaming/Gambling Statements
Under the CGA Code, statements encouraging responsible gaming or gambling must be included in all forms of gaming advertisements in a clear and conspicuous manner, and, at a minimum, all advertisements should feature the statement, "Play responsibly."18
5. Inducements
The CGA Code prohibits the advertisement of inducements, such as bonuses, credits, rewards, and similar promotional offers that persuade or encourage a person to participate or learn more about a gaming site or activity.19 Inducements are only permitted in limited circumstances, such as on the advertiser's direct gaming site, on age-gated affiliated sites where permitted by law, and through direct marketing sent to verified players who have provided active consent.20
To prevent violations arising from user-generated content, operators are advised to either disable the comment section on social media posts or implement active monitoring protocols to promptly identify and remove any comments that promote gambling inducements.21
Enforcement
Starting January 1, 2026, consumers, other advertisers, or advocacy groups can submit complaints to Ad Standards regarding gaming-related advertising that they suspect violates the CGA Code.22 Upon receipt of a complaint, and following a preliminary assessment by Ad Standards indicating a potential breach of the CGA Code, the complaint shall be referred to the advertiser and a formal review process will be initiated.
If Ad Standards concludes that an advertisement violated the CGA Code, the advertiser will be notified of the decision in writing, with a copy to the complainant. The advertiser will be required to appropriately amend the advertising in question or withdraw it, in either case it must do so without unreasonable delay. If Ad Standards determines that the complaint has no merit, both the complainant and the advertiser will be notified in writing and provided with the reasoning behind the decision.23
Advertisers may appeal a decision to the Standards Council, however, the advertisement in question must be withdrawn from circulation while the appeal is under review.24 If an advertiser fails to comply with the final decision, Ad Standards may take any of the following steps:25
- Notify the relevant media outlet of the advertiser's non-compliance and request its cooperation in ceasing to publicize the advertisement in question;
- Issue a public statement, in such manner as Ad Standards deems appropriate, declaring that the advertiser and the advertisement in question, have been found to be in violation the CGA Code; and/or
- Inform the CGA of the advertiser's failure to co-operate, at which point the CGA may take any action it deems appropriate in accordance with the CGA Member Code of Conduct.26
Separately, Ad Standards' Canadian Code will continue to apply to the content of gaming advertising. This 14 clause code addresses issues somewhat separate from the CGA Code such as, accuracy and clarity, safety and unacceptable depictions and portrayals in advertising. Consumer complaints that a gaming advertisement contravenes the Canadian Code will be handled by Ad Standards under a different consumer complaints procedure than complaints under the CGA Code. Ad Standards recently published a document called Gambling Advertising Complaints: A Three-Year Review (April 2022 to April 2025) (Three Year Report). The Three Year Report provides an overview of complaints received about gaming advertising under the Canadian Code in the three years following Ontario's launch of the iGaming market. It is an instructive document for the industry.
Conclusion
As Ad Standards reviews submitted complaints, compliance with the CGA Code will be evaluated on a case-by-case basis. Notably, the CGA Code is intended to be a living document, which means that it will be reviewed every three years,27 allowing for updates that respond to common complaints and reflect evolving industry practices. As Ad Standards begins to receive and assess complaints, additional guidance may be issued to address emerging areas of concern.
Advertisers operating within the gaming sector should be aware that the CGA Code operates in conjunction with applicable federal, provincial, and broadcast regulations, and should review the Three Year Report for an understanding of the concerns of Canadian consumers around gaming advertising. A comprehensive understanding of the broader regulatory framework is essential, particularly in light of increasingly complex and multi-platform advertising practices.
For advice on how the CGA Code may impact your business, please contact a member of the Cassels Regulatory Group.
Footnotes
1 Canadian Gaming Association, Code for Responsible Gaming Advertising (October 2025), online: https://adstandards.ca/resources/library/about-cga-code/ ("CGA Code").
2 Ad Standards, The Canadian Code of Advertising Standards, online: https://adstandards.ca/code/the-code-online/.
3 CGA Code, p. 2, "Scope".
4 CGA Code, p. 2, "Scope".
5 CGA Code, p. 3, "Exclusions".
6 CGA Code, p. 3, "Exclusions".
7 CGA Code, Clause I, s. 1.
8 CGA Code, Clause I, s. 2.
9 CGA Code, Clause I, s. 3.
10 CGA Code, Clause II, s. 1.
11 CGA Code, Clause II, s. 3.
12 CGA Code, Clause II, s. 6.
13 CGA Code, Clause II, s. 7.
14 CGA Code. Clause III, s. 1.
15 CGA Code, Clause III, ss. 2 & 4.
16 CGA Code, Clause III, s. 5.
17 CGA Code, Clause III, s. 3.
18 CGA Code, Clause IV, s. 1.
19 CGA Code, Clause V, s. 1.
20 CGA Code, Clause V, s. 1.
21 CGA Code, Clause V, s. 2.
22 Ad Standards, Complaint Procedure under the Code for Responsible Gaming Advertising, online: https://adstandards.ca/complaints/cga-code-complaints-procedure/ ("Complaint Procedure").
23 Ad Standards, Complaint Procedure.
24 Ad Standards, Complaint Procedure.
25 Ad Standards, Complaint Procedure.
26 Canadian Gaming Association, Join CGA, online: https://canadiangaming.ca/join-cga/.
27 CGA Code, Preamble.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
