Minors in Corporate Advertising

Relevant Standard(s): 2.1
Application: All
 

Issue:

Do the Registrar’s Standards apply to OLG’s corporate awareness initiatives?

If so, which Standards are applicable? The Registrar’s Standards for Gaming completely prohibit the inclusion of underage individuals in advertising and marketing materials, while the Standards for Lottery do not, as long as minors are not used directly to promote gambling and are not depicted as players or purchasers.

Response:

Standard 2.1 is intended to ensure that advertising does not target underage or self-excluded individuals to participate in lottery schemes. As such, corporate awareness initiatives that do not advertise gambling products or services (such as OLG’s “All for Here” campaign) are not covered by Standard 2.1.

Relevant Standard Excerpt(s):

Registrar’s Standards for Gaming:

2.1 Advertising and marketing materials and communications shall not target underage or self-excluded persons to participate in lottery schemes and shall not include underage individuals.

Requirements – At a minimum, materials and communications shall not:

  1. Be based on themes, or use language, intended to appeal primarily to minors.
  2. Appear on billboards or other outdoor displays that are directly adjacent to schools or other primarily youth-oriented locations.
  3. Contain cartoon figures, symbols, role models, and/or celebrity/entertainer endorsers whose primary appeal is to minors.
  4. Use individuals who are, or appear to be, minors to promote gambling.
  5. Appear in media and venues directed primarily to minors, or where most of the audience is reasonably expected to be minors.

Registrar’s Standards for Lottery:

2.1 Advertising and marketing materials and communications shall not target underage or self-excluded persons to participate in lottery schemes.

Requirements – At a minimum, materials and communications shall not:

  1. Be based on themes, or use language, intended to appeal primarily to minors.
  2. Appear on billboards or other outdoor displays that are directly adjacent to schools or other primarily youth-oriented locations.
  3. Contain cartoon figures, symbols, role models, and/or celebrity/entertainer endorsers whose primary appeal is to minors.
  4. Use individuals who are, or appear to be, minors to promote gambling.
  5. Appear in media and venues directed primarily to minors, or where most of the audience is reasonably expected to be minors.

Persons depicted as lottery purchasers or players in lottery advertising should not be, nor appear to be, minors.


This interpretation is provided for informational purposes only and does not constitute legal advice. The interpretation relates to a specific set of circumstances and the standards, laws and regulations in force at the time the interpretation was issued; however, it is not an exhaustive or definitive interpretation of the standard(s) referenced herein.

The AGCO has established the Standards Interpretation Protocol, which acts as a single point of contact for inquiries from the gaming industry related to the interpretation of the Standards. For more information, please contact the AGCO’s Customer Service Department at 416 326-8700 (in the GTA) or 1 800 522-2876 (toll free in Ontario).

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