An academic study conducted jointly by City University of Hong Kong and the University of Bristol revealed that about 11% of Dutch gambling advertisements placed on Meta's Facebook and Instagram platforms may violate the country's strict age-targeting regulations. Using advertisement library data mandated by the EU's Digital Services Act, the research team analyzed 277 paid advertisements posted by licensed Dutch gambling operators from 2024 to early 2025, finding that 31 ads reached the protected age group of 18 to 23 years old—a demographic strictly prohibited from being targeted by Dutch gambling laws. More troubling is the clear compliance gap between online and offline licensed operators: online gambling licensees had a compliance rate of 92.7%, while offline operators had a nearly 30% violation rate.
A single advertisement from Holland Casino reached 21,000 young users
The most glaring case disclosed in the study came from the Dutch state-owned casino giant, Holland Casino. One of its advertisements was estimated to have reached over 21,000 Dutch users aged 18 to 24, with researchers estimating that more than 15% of the total reach in the Netherlands were likely under 24 years old. This exposure directly challenges the core principles of the gambling advertisement protection wall gradually built since 2013, when the "Gambling Recruitment, Advertising and Addiction Prevention Decree" explicitly prohibited targeting individuals under 24 with gambling ads. The law was further amended in 2023 to require online licensees to ensure that at least 95% of their ad audience is over 24 years old.
Dual flaws in platform tools and human errors
The research team attributed the violations to three levels of failure. The fundamental system flaw stems from Meta's own automated ad optimization tools—some operators used the Advantage+ feature, which by default sets the minimum age threshold at 18 instead of the 24 required by Dutch law, leading advertisers to unintentionally step into compliance pitfalls. The second level involves human errors and inconsistent internal audits—different operators vary in the rigor of their compliance checks before ad publication, and some advertisers' operational oversights led to incorrect age settings not being detected in time. The top structural barrier comes from a fatal mismatch in platform data accuracy—Meta's age range reporting uses a broad grouping of 18 to 24 years, whereas Dutch law specifically targets the 18 to 23 age group, creating a gap between statistical standards and legal definitions that makes it difficult for advertisers and external monitors to verify compliance accurately.
The research team thus proposed four policy recommendations directly addressing this systemic tension—requiring platforms to provide reach data by individual age increments to enable full compliance verification and allow queries for any age range, suggesting platforms automatically apply the legal minimum age threshold of the destination country to prevent Dutch gambling ads from default reaching users under 24, urging Dutch regulatory authorities to clarify the control of offline licensees' social media advertising and initiate related compliance investigations, and encouraging regulatory bodies to leverage the transparency tools provided by the Digital Services Act to prioritize deployment of enforcement resources.
PASA official website continues to track global gambling advertisement regulations and social media compliance dynamics, noting that this academic study based on DSA transparency tools is providing a practical methodological template for auditing gambling advertisement compliance within other EU jurisdictions.
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This article is from "PASA-Global iGaming Leaders," a gambling industry news channel: https://t.me/pasa_news
Original in-depth gambling channel: https://t.me/gamblingdeep
Free data reports: @pasa_research
PASA Matrix: @pasa002_bot
PASA official website: https://www.pasa.news
