Last updated 26 September 2026 — by Adrian Tan, SDM. Marketing guidance, not legal advice. The Gambling Control Act 2022 is enforced by the Gambling Regulatory Authority and the Singapore Police Force, and several of the offences below carry strict liability; if you are asked to run a campaign that touches betting, gaming or a lottery, the question of whether the operator is licensed goes to a lawyer before it goes to a media plan.
Most of the Singapore advertising regimes we have covered are aimed at the business being advertised. The travel agent must carry its licence number. The moneylender may only use three channels. The health product must not claim to treat a named disease. The advertiser carries the duty and the agency follows the brief.
The Gambling Control Act 2022 is built the other way round. Its advertising offence is aimed squarely at the people in the middle: the affiliate site, the tipster channel, the influencer with a referral code, the media buyer, the sponsor whose logo appears on a jersey. The operator it is really concerned with is usually offshore, unlicensed and out of reach. The people promoting that operator to Singapore users are not.
The offence: section 85 and what “advertises” means
Section 2 of the Act lists its purposes, and one of the five is simply “to prohibit advertising of unlawful gambling”. Section 85(1) delivers it: a person commits an offence if the person advertises any unlawful gambling. The maximum is a fine of $20,000, and section 85(7) provides that strict liability applies — the prosecution does not need to prove you knew the operator was unlicensed.
The meaning of “advertises” in section 85(3) is where the breadth lives. A person advertises unlawful gambling if the person:
- (a) informs the public of any place or any online location where unlawful gambling takes place or an unlawful gambling service is provided;
- (b) invites the public to engage in unlawful gambling, to seek information about opportunities to do so, to commit money to it, or to seek information about committing money to it;
- (c) with a view to increasing use of the facilities, brings information about them to the attention of one or more persons;
- (d) participates in or facilitates an activity knowing or believing it is designed to encourage people to use, or to increase use of, unlawful gambling facilities; or
- (e) publishes a gambling advertisement about unlawful gambling or an unlawful gambling service.
Limb (c) needs only “one or more persons”, so a single direct message can do it. Limb (d) reaches someone who publishes nothing but facilitates an activity they know is designed to promote an unlawful service — a media buyer, a production house, an ad-ops contractor and an agency account manager.
Section 85(4) closes the “nobody saw it” argument. Posting a gambling advertisement on an online location that enables dissemination to the public counts as informing the public “whether or not the particular publication results in the dissemination of information to the public”. A post with no reach is still a post.
What counts as a “gambling advertisement” — a URL is enough
Section 16(1) defines a gambling advertisement as any information or material that gives publicity to, or otherwise promotes or is intended to promote, any of five things:
| Limb | What it promotes | What it catches in practice |
|---|---|---|
| (a) | A particular gambling service | The obvious case: a banner, a video or a post for a named betting site or app. |
| (b) | Gambling services in general | “Best betting sites” listicles, comparison tables and generic “bet on the match” content. |
| (c) | The whole or part of a trade mark relating to a gambling service | A logo on merchandise, a jersey, a stream overlay or a thumbnail — with no call to action at all. |
| (d) | A domain name or URL of a gambling service | A bare link in a bio, a caption, a video description or a pinned comment. |
| (e) | Words closely associated with a particular gambling service | A slogan, a promo code or a nickname that the audience recognises as the operator, even where the operator is not named. |
Section 16 also defines a separate concept, the “inducement to gamble”: a document or message containing an offer of credit, a voucher, a reward or other benefit to gamble; an offer designed to induce people to participate or increase participation; an offer of an opportunity to gamble with added benefits; or an invitation to gamble or to seek information for the purpose of gambling. Sign-up bonuses, free bets, deposit matches and “tips” channels that route to a bookmaker all sit here. It matters most for the under-age offence, below.
When an advertisement made abroad is “published in Singapore”
Running a campaign from abroad is not a defence. Sections 16(2) and 16(3) are drafted to remove it.
For electronic advertisements, section 16(3) sets two alternative tests:
- It originates in Singapore — in which case it is published here even if none of the people who can access it is physically in Singapore. A Singapore-based agency or creator running a campaign aimed entirely at another market is still publishing in Singapore.
- It originates elsewhere (or its origin cannot be determined), and both (i) it is made available by, or with the participation of, a Singapore-connected person, and (ii) it is accessible by persons physically present in Singapore.
Section 16(5) defines a Singapore-connected person as a citizen, a permanent resident, any person physically present in Singapore, an entity incorporated or registered in Singapore (even if incorporated elsewhere), or a corporation established under a private Act. So a Singaporean creator living overseas, a foreign freelancer who happens to be working from a Singapore co-working space, and a foreign company with a registered Singapore branch can each turn an offshore advertisement into one published here.
What is not a gambling advertisement: the six carve-outs
Section 16(4) lists activities that do not, of themselves, amount to publishing a gambling advertisement or sending an inducement to gamble. They are narrow, and each has a marketing edge worth knowing:
- Trade-only communications — material sent to a group of people all of whom are involved in providing gambling services. One outsider on the mailing list and the carve-out fails.
- Directory listings — publishing a gambling provider’s name in a telephone directory, unless the listing is on the internet and links to an online location where the person conducts remote betting, gaming or a lottery. An online directory entry with a link is back in scope.
- Organic search results — an index of search results that points a Singapore user to gambling “only because that person initiates a search” through a search engine service. Note what this does not cover: paid search ads, sponsored listings, SEO content written to rank for “betting sites Singapore”, or the pages the search result leads to. The carve-out protects the search engine’s index, not the marketer who games it.
- Venue signage — words or symbols in or on an approved gambling venue occupied by a licensee or its agent.
- Corporate notices — an advertisement about a licensee’s internal management that does not promote a gambling service, such as a recruitment advertisement or a call for tenders.
- Anti-gambling messages — material whose sole or principal purpose is apparent from its contents to be discouraging gambling.
The search carve-out is worth dwelling on because it is the one most often misread. It does not make gambling SEO lawful: an affiliate page built to rank for Singapore betting queries is a gambling advertisement under limbs (a) and (b); if it originates here or involves a Singapore-connected person and is accessible here, it is published in Singapore; and if the operators it recommends are unlicensed, section 85(3)(e) is engaged.
Sponsorship and brand-sharing: the logo on the shirt
Section 85(5) deals specifically with the most common form of gambling marketing in football and esports. For the purposes of limbs (c) and (d), a person is treated as bringing gambling facilities to people’s attention with a view to increasing their use if the person enters into arrangements — “whether by way of sponsorship, brand-sharing or otherwise” — under which a name is displayed in connection with an event or product, and either:
- providing gambling facilities is the sole or main activity undertaken under that name; or
- the manner or context in which the name is displayed is designed to draw attention to the fact that gambling facilities are provided under it.
This is aimed at the “white-label” workaround, in which a betting brand sponsors an event under a name that belongs to a news, streaming or “tips” arm. If the main activity under that name is gambling, or the context is designed to point at it, the arrangement is caught. For a Singapore event organiser, club or esports team, the question is not whether the sponsor’s logo says “bet”, but what the name is mainly used for.
The pre-licence trap: advertising before the paperwork is done
Section 85(6) creates a deeming rule that catches legitimate businesses. An advertisement is deemed to advertise unlawful gambling if, for the gambling to take place as advertised without an offence, it would be necessary to rely on a licence or an exception, and at the time of advertising the arrangements for that licence “have not been completed” and the arrangements for the activity are not such as to ensure an exception applies.
In plain terms: if a promotion, a game or a draw needs a licence or a class licence to be lawful, advertising it before that licence is in place is advertising unlawful gambling — even though the activity, once licensed, would have been fine. For most Singapore brands the practical exposure is not betting at all but trade promotions: a lucky draw or game of chance run to promote a product must fit an exclusion or a class licence, and the promotional material must not run ahead of that. Our guide to lucky draw rules in Singapore covers the trade-promotion conditions in detail; section 85(6) is why the order of operations in that guide matters.
The heaviest limb: inducements sent to anyone under age
The advertising offence carries a $20,000 maximum. The under-age inducement offence is fifteen times heavier.
Section 34(1) makes it an offence to send, or cause to be sent, to an underaged individual any inducement to gamble (other than social gambling). Under section 34(2) the maximum is a fine of $300,000 or imprisonment for up to six years, or both. Section 34(5) applies strict liability. The extra defence in section 34(3) requires both no benefit and that the inducement was not sent in the course of any business, which excludes anyone doing it professionally.
Who counts as underaged is set by section 13 and depends on the type of gambling. On-course and off-course betting on horse racing, and certain place-based lottery and sports betting without a live broadcast at the premises, carry a minimum age of 18. Place-based sports betting with a live broadcast, and any other non-remote or remote gambling not otherwise listed (including in a casino) and not authorised by a class licence, carries a minimum of 21. For online gambling promoted through social media, the working assumption is therefore 21.
Put that next to how inducements are actually distributed: a bonus code in a creator’s story, a “free bet” message blasted to a Telegram channel, an email to a scraped list, a retargeting ad with a deposit match. None of those channels verifies age. If the audience includes anyone under 21 and the offer is an inducement to gamble, the sender is exposed to the six-year limb regardless of what they intended. Our guide to age assurance and marketing to minors covers the platform side of the same problem.
The four defences, and which ones an agency can actually use
Section 86 sets out the defences to sections 34 and 85. Each must be proved by the person charged, on a balance of probabilities — the burden is on you, which is why documentation matters.
| Defence | Applies to | What you must prove |
|---|---|---|
| s 86(1)(a) — licensee’s direction | ss 34 and 85 | You published the advertisement or sent the inducement for, or on the direction of, a licensee or class licensee |
| s 86(1)(b) — mere conduit | ss 34 and 85 | You deliver, transmit or broadcast material or make data available, in a business whose nature gives you no control over content |
| s 86(2) — incidental | s 85 only | The ad appeared as an accidental or incidental accompaniment to other matter, and you received no extra benefit for it |
| s 86(3) — innocent publisher | s 85 only | You are in the business of publishing or arranging ads, received it in the ordinary course, have no financial interest in the gambling, did not know it was unlawful, and took all reasonably practicable steps to check |
Two things stand out. First, neither the incidental nor the innocent-publisher defence is available for the under-age inducement offence — section 86(2) and (3) apply to section 85 only. Second, the innocent-publisher defence fails for anyone with a financial interest in the gambling. An affiliate paid on revenue share or cost per acquisition has, almost by definition, a financial interest in the gambling it promotes, which is why the affiliate model sits outside the one defence designed for the advertising trade.
After the fact: corrective orders, site blocking and payment blocking
- Corrective measures (s 87). Where a person has advertised or caused advertising of unlawful gambling — whether or not an offence is committed — the Authority may order the person to stop immediately, to take reasonable measures to remove advertisements already published in Singapore, and to publish a corrective advertisement in a manner and with content the Authority specifies. The person bears the cost. Failing to comply is an offence carrying up to $50,000 or two years, and the Authority may do the work itself and recover the cost.
- Access and payment blocking. The Authority may direct IMDA to order internet service providers to disable access to an online location that is a remote gambling advertisement published in contravention of section 85, and may move against the bank accounts and payment flows behind it.
Licensed operators, casinos and the prior-approval rule
The Gambling Regulatory Authority’s position is stated plainly: all forms of advertising and promotion by licensed gambling operators are prohibited unless otherwise approved by the GRA. The Act gives that position teeth through licence conditions. A licence or class licence may require advertisements about the licensed service to be published only to certain classes of persons, to contain specified words, to exclude certain content, not to appear in certain publications or media, and to be approved by the Authority before publication in Singapore.
Casinos sit under a separate regime. Section 170A of the Casino Control Act 2006 provides that a person must not carry out any advertising or promotional activities relating to a casino except with the Authority’s approval and in accordance with regulations. Casino operators and licensed agents who breach it face disciplinary action; any other person required to comply who fails to do so commits an offence carrying a fine of up to $10,000. An agency, event partner or creator running casino promotion is therefore inside the approval requirement too, not merely the operator.
Worked example: two briefs an SME agency might receive
Brief 1 — a football-content creator. A Singapore-based creator with a 70% Singapore audience is offered a monthly fee by an offshore sportsbook to add a link to their bio, show the brand’s mark on stream, and read a sign-up bonus code once per video. Every element is caught: the link (s 16(1)(d)), the mark (s 16(1)(c)), the code as an inducement (s 16), and the content originates in Singapore (s 16(3)(a)). If the audience includes anyone under 21 — and a football audience will — the bonus code engages section 34. The monthly fee is a financial interest, so the innocent-publisher defence is unavailable. Decline.
Brief 2 — a restaurant chain’s World Cup promotion. A chain wants a “predict the score, win a dinner” campaign on Instagram, free to enter. This is not a betting operation, but it may be a game of chance or a lottery depending on how winners are chosen. It should be structured to fall within an exclusion or class licence before the creative is published, or section 85(6) deems the advertising unlawful. Proceed, in the right order.
A pre-brief checklist
- Screen every sponsor and advertiser against the question “is any part of this business a gambling service?” before contract, including sister brands under shared names.
- Record the licence check for any gambling-adjacent client: the licence or class licence relied on, the date, and who checked. This is your s 86(3) evidence.
- Never run bonus codes, free-bet offers or deposit matches to an unverified audience — s 34 is strict liability with a six-year maximum.
- Exclude gambling terms and brands in paid search and audit automatically generated placements.
- Put a gambling-sponsor exclusion in every creator contract, and audit link hubs, pinned comments and overlays, not just the video.
- Sequence trade promotions: exclusion or class licence first, creative second.
Frequently asked questions
Is it illegal to advertise gambling in Singapore?
Advertising unlawful gambling is an offence under section 85 of the Gambling Control Act 2022, with a maximum fine of $20,000 and strict liability. Advertising by licensed operators is not banned outright, but the Gambling Regulatory Authority states that all advertising and promotion by licensed operators is prohibited unless it approves it, and licence conditions can restrict the audience, content and media and require prior approval.
Can an influencer in Singapore promote an overseas betting site?
If the site is not licensed for Singapore, promoting it is advertising unlawful gambling. Section 16 treats a link, a domain name, a trade mark or words closely associated with the service as a gambling advertisement, and an electronic advertisement that originates in Singapore is published here even if nobody in Singapore sees it. Sending a sign-up bonus to anyone underage also engages section 34, which carries up to $300,000 or six years’ imprisonment.
Does the law apply if my campaign targets another country?
Yes, if it originates in Singapore. Section 16(3)(a) provides that an electronic gambling advertisement originating in Singapore is published in Singapore even if none of the people who can access it is physically present here. For campaigns originating elsewhere, it applies where a Singapore-connected person takes part and the advertisement is accessible from Singapore.
Are Google search results for betting sites illegal?
No. Section 16(4)(c) provides that an index of search results shown only because a user initiated a search does not, of itself, amount to publishing a gambling advertisement. That protects the search engine’s organic index. It does not cover paid search advertisements or content created to rank for gambling queries.
What defences are available to an advertising agency?
Section 86 allows a defence where the agency acted for or on the direction of a licensee or class licensee, and, for the section 85 offence only, where it is in the business of publishing advertisements, received the ad in the ordinary course, has no financial interest in the gambling, did not know it was unlawful and took all reasonably practicable steps to check. The last two defences are not available for the under-age inducement offence.
The takeaway
Singapore’s gambling advertising law is unusual because it treats the promotion itself as the thing to police, and the people doing the promoting as the people to hold responsible. The definitions are drafted for how gambling is actually marketed now: a URL is an advertisement, a logo is an advertisement, a promo code is an inducement, and a campaign that starts in Singapore is published in Singapore wherever its audience is.
For most businesses the practical risks are indirect — a creator contract without an exclusion clause, a sponsorship with a sister brand, a trade promotion advertised before it was structured, a community channel full of spam links. For anyone who takes gambling money, the risk is direct, the liability is strict, the affiliate model forfeits the publisher’s defence, and the under-age limb carries six years.
If you run performance campaigns in Singapore and want the exclusions, placement audits and creator contracts set up properly, that is part of what our performance marketing team does; see our client case studies. Start with our guide to performance marketing in Singapore, then the adjacent rules: influencer and KOL marketing, crypto marketing rules, moneylender advertising rules, tobacco and vape advertising, the online advertising Codes of Practice and competitor brand bidding.
