ANJ Advertising Rules: What French Licensees Must Change in 2026

No primary ANJ source we reviewed shows a single circular that opens a Q3 2025 advertising enforcement window. France tightens gambling advertising through three layers: binding provisions of the Code de la sécurité intérieure (CSI), the annual approval of each licensee’s promotional strategy, and soft law in Communication n° 2022-C-002 and the four November 2022 charters. As of October 2026, the live pressure point is budget and content discipline inside the annual approval, and licensees should rebuild their filings around that. This briefing separates what is binding from what is recommended, then sets out a change list.

The analysis rests on a reading of ANJ Communication 2022-C-002, the ANJ 2023 annual report, ANJ’s 7 October 2026 announcement with the ARPP, and a Conseil des prélèvements obligatoires note on gambling taxation. Individual approval decisions are confidential, so any 2026 condition described below comes from press reporting and is labelled as such.

Is there a Q3 2025 ANJ advertising circular?

No. We found no ANJ circular, decision or communication dated to Q3 2025 that sets a new advertising rule or an enforcement date. The ANJ instrument that governs advertising conduct is Communication n° 2022-C-002 of 17 February 2022, which adopted recommendations on the commercial communications of licensed operators and holders of exclusive rights.

The one ANJ enforcement milestone from July 2025 concerns something else. ANJ states on its news feed that in July 2025 it referred a licensed operator to the national sanctions commission for the first time, over anti-money laundering obligations, and its news item of 21 September 2026 reports the commission’s first sanction against a licensed operator.

The binding layer: annual strategy approval and the CSI

As of October 2026, every licensed operator, and FDJ and PMU under exclusive rights, must submit its promotional strategy to ANJ each year for approval. The Conseil des prélèvements obligatoires note on gambling taxation describes the filing as a document presenting the operator’s promotional strategy across all media, and notes that ANJ can order an operator to withdraw any commercial communication. According to SBC News on 8 October 2026, the charter regime requires campaign plans to be submitted six months in advance.

The ANJ 2023 annual report states the decision options. The collège can approve the strategy outright, approve it subject to conditions, or reject it, in which case the operator must file a new dossier within one month. The report adds that failure to respect the conditions can lead ANJ to refer the matter to its sanctions commission under article 43 of the law of 12 May 2010.

The 2023 review covered 17 licensed online operators plus FDJ and PMU. ANJ found that all had respected its guidelines and recommendations overall, yet the collège rejected FDJ’s strategy for its monopoly activity because it was not sufficiently measured and limited. A new FDJ request was examined and approved in May 2023.

The CSI supplies the hard content rules. Article D.320-10, 3°, prohibits in gambling commercial communications any staging of personalities or characters belonging to the world of minors. Articles L.320-11 and L.320-12 require a warning message on the risks of excessive or pathological gambling in commercial communications. The Conseil des prélèvements obligatoires note, citing articles D.320-1 and following, adds that advertisements must carry a banner covering at least 7% of the screen height with the warning. A health ministry order on the content and display of the warning was still pending when ANJ issued Communication 2022-C-002.

Influencer rules sit in the same binding layer. The ANJ 2023 annual report records that failure to show a clear “publicité” or “collaboration commerciale” mention is punishable by the administrative fine in article L.324-8-1 CSI, up to €100,000. It also records that promoting subscriptions to sports tips is a criminal misleading commercial practice under the Consumer Code.

The soft-law layer and the ARPP’s role

Communication 2022-C-002 followed the June 2021 European football championship, a public consultation, and Kantar and Harris Interactive studies commissioned by ANJ. Its diagnosis is stated in the text.

“l’Autorité relève une intensification inédite de la pression publicitaire, en particulier s’agissant des communications commerciales relatives aux paris sportifs.” (ANJ Communication n° 2022-C-002, 17 February 2022. In English, the Authority notes an unprecedented intensification of advertising pressure, particularly for sports betting communications.)

ANJ chose recommendations because, in its own words, existing guidelines could not address the intensity and distribution of gambling advertising and no specific legislative or regulatory provision existed. It also stated that the recommendations will be adapted in light of its yearly evaluation of operators’ promotional strategies, and that operators’ compliance is assessed each year during approval of the strategy.

The table maps the instruments a compliance team should set against its annual filing. Figures and thresholds are those stated in the sources named in each row, as of October 2026.

Instrument	Content	Status	Source
CSI D.320-10, 3°	No staging of personalities or characters from the minors’ universe	Binding	CSI
CSI D.320-1 et seq.	Warning banner of at least 7% of screen height	Binding	Conseil des prélèvements obligatoires note
Annual promotional strategy	Approval, approval with conditions, or rejection with refiling within one month	Binding	ANJ 2023 annual report
CSI L.324-8-1	Fine of up to €100,000 for missing influencer disclosure	Binding	ANJ 2023 annual report
Communication 2022-C-002	Three commercial communications per day per medium online and on VOD, influencers under 16% audience share aged 13 to 17, ARPP influence certificate	Recommendation	ANJ, 17 Feb 2022
ANJ guidelines on bonuses and athletes	Welcome bonus limited to €100, no depiction of athletes, coaches or referees betting	Guideline, sanctionable per the note	Conseil des prélèvements obligatoires note
Four engagement charters (Nov 2022)	Television, radio, outdoor and digital advertising commitments	Voluntary commitments, under review	ANJ and ARPP, 7 Oct 2026

The Communication’s recommendations are specific. For online services it invites operators to limit themselves to three commercial communications per day and per medium (website, mobile app, social platform, search engine). For video on demand it proposes three per day and per channel consulted. In broadcast advertising breaks it recommends no more than one commercial communication per operator, and it proposes an advertising moderator that lets players choose the number, frequency and type of notifications at registration.

On influencers, ANJ recommends that operators use only ambassadors whose audience share aged 13 to 17 is below 16%, and who hold the ARPP “Certificat Influence Responsable”. The 2023 annual report adds that ANJ also asks for a contract clause in which the influencer attests knowledge of, and undertakes to respect, the gambling advertising rules. The same report notes 57 influencers under contract with gambling operators in 2024, against 121 in 2023.

On 7 October 2026, ANJ President Pascal Chevremont and ARPP President Christine Albanel renewed the convention first signed in 2023. ANJ states that the ARPP is the operators’ first point of contact on commercial communication projects before broadcast, and may seek ANJ’s view where it doubts compliance.

“L’ARPP constitue le premier interlocuteur des opérateurs de jeux d’argent et de hasard concernant leurs projets de communications commerciales avant diffusion.” (ANJ, 7 October 2026)

The renewed convention brings JONUM (jeux à objet numérique monétisable) into scope, provides for ANJ to act to strengthen the gambling module of the ARPP commercial influence certificate, and associates the ARPP with ANJ’s review of the four charters signed in November 2022 for television, radio, outdoor and digital advertising.

Where ANJ practice goes beyond its published text

The Conseil des prélèvements obligatoires note observes that, despite the silence of the law and regulation, ANJ recommends not depicting athletes, coaches and referees in a betting situation and limiting financial welcome bonuses to €100, on pain of administrative sanctions. The same note says sponsorship rules rest essentially on ANJ guidelines, including avoiding operator naming of sports infrastructure and competitions and keeping operator brands off children’s-size shirts. These are interpretive acts, and in practice their force comes from the approval conditions rather than from a statute.

The 2026 budget measures follow the same pattern. According to SBC News on 8 October 2026, ANJ ordered all licensed operators not to exceed their declared promotional budgets and set strict limits on spending between marketing categories. Sigma.world headlined on 9 January 2026 that ANJ had set its first-ever cap on betting advertising spend for the 2026 World Cup, we could read the headline only. We could not retrieve the underlying ANJ decisions, so the cap mechanics, amounts and category definitions are unverified.

The commercial context explains the pressure. ANJ’s news feed of 23 July 2026 reports record online stakes of €1.3 billion at the 2026 World Cup, against a pre-tournament projection of about €1.2 billion reported in June 2026. In coverage of ANJ’s survey that month, 82% of respondents supported banning betting adverts on television from five minutes before kick-off to five minutes after the final whistle, and 77% backed a commitment to ban adverts during three-minute mid-half breaks. According to iGamingBusiness, ANJ has called for a whistle-to-whistle ban. SBC News reported on 8 October 2026 that Mr Chevremont, appointed by decree of 22 June 2026, will assess collected data before deciding whether to review French advertising law, practice and guidelines.

Reporting on ANJ’s new algorithm adds that about 600,000 players showed a high probability of excessive gambling in the second half of 2025, 8.7% of online account holders, and generated roughly 60% of gross gaming revenue. In practice, a regulator holding that finding is likely to treat promotional exposure as a harm variable, not only a marketing one.

The counter-argument, taken seriously

Operators have three credible objections. The legal objection is that the 2022 recommendations are expressly recommendations, ANJ itself acknowledged the absence of specific legislative or regulatory provisions, and the law sets no bonus ceiling. Whether the 2026 budget orders rest on a statutory basis cannot be confirmed from the sources reviewed, and if they do not, they invite challenge. The ANJ 2023 annual report nevertheless records that conditions attached to an approval can be referred to the sanctions commission, which is the route any challenge would have to confront.

The channelisation objection is that advertising exists to steer players to the legal offer. The Conseil des prélèvements obligatoires note records that the legislator authorised advertising for that purpose and did not ban bonuses because unlicensed foreign operators would ignore the ban. The same tension appears in our analysis of Sweden’s channelisation problem. The note shows French policy accepting the argument in principle, which is why ANJ regulates volume and content rather than prohibiting advertising.

The third objection is that no whistle-to-whistle ban exists. That is correct as of October 2026. A licensee that treats the absence of a ban as permission, however, faces a regulator that has publicly campaigned for one and controls the annual approval.

What licensees should change now

Reconcile the declared promotional budget with actual and committed spend, by category, before the next filing. Where ANJ ordered licensees not to exceed declared budgets, the filing operates as a ceiling. Finance and compliance should hold one version of the number, and any reallocation between categories should be checked against the approval conditions first.

Map every condition in the current approval letter to a named owner and a monitoring control. Under the ANJ 2023 annual report, breach of an approval condition is the route to the sanctions commission.

Test the commercial communications calendar against the 2022 recommendations. That means a daily cap of three communications per medium to each user, a single operator communication per broadcast advertising break, and an advertising moderator at registration. These are recommendations in form, but ANJ states it assesses them at each annual approval.

Re-screen every influencer and ambassador. Confirm the audience share aged 13 to 17 is below 16% on every medium, that the ARPP certificate is held, and that the contract contains the attestation clause. Missing disclosure carries the administrative fine of up to €100,000 under L.324-8-1 CSI as of October 2026, and the October 2026 convention points to a tighter gambling module in the certificate.

Audit bonus and athlete creative against ANJ guidelines. As of October 2026, welcome bonuses should sit at or below €100, and no athlete, coach or referee should appear in a betting situation. Check creative against D.320-10, 3°, and verify the warning banner covers at least 7% of screen height.

Build an ARPP pre-broadcast step into the campaign workflow, document the outcome, and log any case where the ARPP consulted ANJ. Add any JONUM product to the same workflow now that it falls within the convention.

Prepare a scenario for a whistle-to-whistle restriction, with media plans that can drop pre-kick-off, in-match and post-match inventory without breaching declared category budgets. ANJ has not imposed the ban, but a rejected strategy carries a one-month refiling window.

Frequently asked questions

Did ANJ publish a circular with a Q3 2025 advertising enforcement deadline? We found none in ANJ’s primary materials. ANJ’s July 2025 milestone was a first referral to the sanctions commission on anti-money laundering, not advertising.

Are the ANJ 2022 advertising recommendations legally binding? Communication 2022-C-002 is framed as recommendations, issued in the absence of specific legislative or regulatory provisions. They carry practical force because ANJ evaluates each operator’s annual promotional strategy against them, and conditions attached to an approval can be referred to the sanctions commission.

What is the welcome bonus limit in France? As of October 2026, the Conseil des prélèvements obligatoires note reports that ANJ recommends limiting financial welcome bonuses to €100, on pain of administrative sanctions, despite the silence of the law and regulation.

Does France ban advertising during live matches? No ban exists as of October 2026. ANJ has called for a whistle-to-whistle ban, and its president has said he will assess data before deciding on a wider review of advertising rules.

Key Resources

ANJ, news release of 7 October 2026 on the renewed ANJ and ARPP convention (anj.fr). ANJ, Communication n° 2022-C-002 of 17 February 2022 on recommendations for commercial communications. ANJ, Rapport annuel 2023, section on promotional strategies and influencers. Conseil des prélèvements obligatoires, note on rationalising gambling taxation. Code de la sécurité intérieure, articles L.320-11, L.320-12, L.324-8-1 and D.320-1 et seq. Secondary reporting: SBC News, 8 October 2026, sigma.world, 9 January 2026, iGamingBusiness coverage of ANJ’s 2026 prevention campaign. For a step-by-step guide to preparing your promotional strategy filing, see our checklist on ANJ promotional strategy compliance.