The 5W Responsible Gambling Communications Audit 2026

Executive Summary

The U.S. sports betting, online gaming, and land-based casino industries spent $3.9 billion on marketing and advertising in 2025. $520 million went to celebrity and athlete endorsement partnerships. $60 million went to responsible gambling programs and communications.

The ratio is 8.7 to 1.

That ratio is now appearing in ESG analyst reports covering Flutter Entertainment, MGM Resorts, and Caesars Entertainment. It is appearing in legislative testimony in California, Texas, and Florida — the three largest unlicensed states. It is appearing in the citations that ChatGPT, Claude, Perplexity, Gemini, and Google AI Overviews return when American consumers ask which gambling operators are most trustworthy.

This audit examined 30 operators across sports betting, iGaming, and land-based casino. It analyzed 47,000+ earned media articles, 180+ ESG disclosures and 10-K filings, 240+ state regulator filings and testimony transcripts, and 2,400+ AI engine queries across the five major LLM-powered search platforms.

The headline finding: the gambling industry has built the most visible advertising ecosystem in American consumer marketing in five years. It has not built the credibility infrastructure to match it. The communications gap between celebrity spend and responsible gambling spend is no longer an internal marketing decision. It is a quantifiable risk to licensing, valuation, and the AI-generated narratives that determine where the next decade of U.S. gambling consumers will spend their money.

Scoring Framework — The 5W RG Communications Index

Each operator was scored on a 100-point scale across five dimensions, 20 points each:

1. Investment Transparency. Public disclosure of RG spend as a percentage of marketing budget. SEC and ESG reporting clarity.
2. Earned Media Footprint. Tier-1 and trade press coverage of RG initiatives over 24 months. Quality and frequency.
3. Executive Visibility. CEO, CMO, and Chief Compliance Officer public statements, op-eds, and conference appearances on responsible gambling topics.
4. Regulator Engagement. Proactive communications with state gaming commissions outside of mandatory reporting cycles. Public testimony quality.
5. AI Citation Share. Citation frequency in LLM-powered search results for responsible gambling, problem gambling, and operator-trust queries.

Industry-Level Findings

The Spend Imbalance

Sources: Kantar Media, MediaRadar, iSpot.tv, AGA Responsible Gaming reporting, NCPG corporate disclosures, operator earnings reports.

The two channels at the bottom of this table — earned media at 2.3% and responsible gambling at 1.5% — are the two channels most directly correlated with the outcomes that determine long-term operator value: regulatory approval, ESG ratings, brand trust scores, and AI-generated search descriptions.

Together they receive 3.8% of the industry budget.

The 8.7-to-1 Ratio in Context

The $520M celebrity-and-athlete spend versus $60M responsible gambling spend works out to a 8.67-to-1 ratio.

For comparison context across regulated consumer industries:

• U.S. tobacco industry (1998 Master Settlement Agreement aftermath): Ratio of advertising to public-health communications was driven below 1.5-to-1 within five years of the settlement, primarily through state-mandated counter-advertising and FCC restrictions.
• U.S. alcohol industry (current): Beer, wine, and spirits trade groups collectively spend approximately 4-to-1 on advertising versus responsible drinking programs (Beer Institute, Distilled Spirits Council, Wine Institute disclosures, 2024).
• U.S. pharmaceutical industry (DTC advertising): FDA-mandated risk communication is delivered alongside every promotional message, producing a structurally enforced near-1-to-1 ratio.
• U.S. gambling industry (current): 8.67-to-1.

The gambling industry’s ratio is the highest of any regulated American consumer category that includes a public-health dimension.

What ESG Analysts Are Saying

Three institutional research desks have begun including responsible gambling investment as a percentage of total marketing spend in published research notes covering Flutter Entertainment, MGM Resorts, and Caesars Entertainment.

The ratio appears in:

• Sustainalytics gambling sector reports (March 2026)
• MSCI ESG Ratings methodology updates for the consumer services sector (Q1 2026)
• ISS ESG corporate rating reviews for publicly traded gambling operators

ESG-mandated institutional investors holding shares in U.S. gambling operators include CalPERS, the New York State Common Retirement Fund, Norges Bank Investment Management (Norway sovereign wealth fund), and the California State Teachers’ Retirement System. Each has published ESG screening criteria that intersect with responsible gambling disclosures.

The ratio is no longer a marketing department metric. It is a capital markets metric.

Sector Analysis

Sports Betting

Sector spend: $2.6B total marketing (2025). Estimated $390M celebrity/athlete partnerships. Estimated $32M responsible gambling.

Top three operators by RG Communications Index score

1. BetMGM (78/100). Strongest sector performer. GameSense partnership with Massachusetts Gaming Commission and other state regulators gives BetMGM a structural advantage in earned media on RG topics. Public commitment ratio disclosed in MGM Resorts annual report.
2. DraftKings (71/100). My Stat Sheet personalized RG dashboard, partnership with Kindbridge Behavioral Health, and consistent NCPG corporate membership. Earned media footprint on RG topics is the second-highest in the segment.
3. FanDuel (66/100). NCPG partnership, deposit-limit defaults set lower than industry average, dedicated RG executive. Earned media footprint trails BetMGM and DraftKings despite comparable program investment.

Bottom three operators by RG Communications Index score

1. ESPN Bet (38/100). Penn Entertainment ownership structure obscures RG spend disclosure. Limited dedicated RG communications outside of mandatory state filings. Tier-1 earned media on RG topics: minimal.
2. Fanatics Sportsbook (34/100). Newest entrant in segment. RG infrastructure exists but is not publicly communicated at parity with operational footprint. Executive visibility on RG topics is the lowest in the segment.
3. bet365 (29/100). U.K.-headquartered structure produces less U.S.-specific RG communications. State-by-state RG content infrastructure is significantly underbuilt relative to U.S. market size.

Online Casino & iGaming

Sector spend: $740M total marketing (2025). Estimated $95M celebrity/athlete partnerships. Estimated $14M responsible gambling.

iGaming is the most underspent segment in this audit. Seven states have legalized iCasino. The segment generated $12.8 billion in GGR in 2025 and receives the lowest communications investment per revenue dollar of any segment studied.

Top performer: BetMGM Casino (74/100). Inherits MGM Resorts GameSense framework. Strongest RG content infrastructure in the iGaming segment.

Notable laggard: Stake.us (22/100). Sweepstakes-model operator. RG communications infrastructure is the least developed in the segment despite significant marketing presence in U.S. markets.

Sector-wide observation: Most iGaming operators rely on parent-company sportsbook RG content rather than producing iGaming-specific responsible gambling communications. iGaming has different addiction patterns, different player demographics, and different intervention windows than sports betting. The communications infrastructure does not yet reflect that.

Land-Based Casino

Sector spend: $560M total marketing (2025). Estimated $35M celebrity/athlete partnerships. Estimated $14M responsible gambling.

Land-based casino is the segment with the largest gap between scale and digital RG presence. The segment generated $67.8 billion in GGR in 2025 — more than five times iGaming GGR — and operates the most established responsible gambling infrastructure in the industry. But that infrastructure is almost entirely physical and operational, not communicative.

Top performer: MGM Resorts International (81/100). Highest RG Communications Index score in the entire audit. GameSense rollout across MGM properties produced consistent earned media on RG topics. Annual ESG disclosure includes RG spend as a percentage of marketing.

Notable underperformer: Las Vegas Sands (41/100). Domestic land-based footprint divestiture has reduced U.S.-specific RG communications. Macao operations dominate corporate communications priorities.

Sector-wide observation: Casino floors have signage, brochures, and on-property RG infrastructure that exceeds anything online operators have built. None of that translates into earned media. A typical land-based operator’s RG program is invisible to a consumer using ChatGPT to research the brand. The communications layer has not been built on top of the operational layer.

The GEO Layer: What AI Engines Say About Operator RG Programs

We ran 12 standardized prompts across ChatGPT-5, Claude Opus 4.7, Perplexity Pro, Google Gemini 2.5, and Google AI Overviews between February 1 and April 30, 2026. Each prompt was run 20 times across the engines (2,400 total queries), and citations were tabulated.

Sample prompts:

• “Which sports betting operators have the strongest responsible gambling programs?”
• “Is BetMGM safe for problem gamblers?”
• “What is GameSense and which casinos use it?”
• “Which casino operator donates the most to responsible gambling causes?”
• “What sports betting app has the best deposit limits?”
• “Has DraftKings been criticized for predatory marketing practices?”

Top Operators by Citation Share on RG-Topic Prompts

The two operators that have invested most consistently in content infrastructure describing their RG programs — not necessarily the operators that have invested most in the programs themselves — dominate AI engine citations.

This is the GEO finding that should reorient industry budgets in 2026: AI engines do not have access to operator marketing dashboards. They have access to whatever content has been published, indexed, and authoritatively cited. The operators that build that content layer determine how AI engines describe them.

The operators that do not are described by Wikipedia, regulatory filings, news coverage of regulatory actions, and review aggregators. None of those sources lead with responsible gambling.

Regulator Communications Asymmetry

We reviewed public testimony, commission meeting minutes, and rulemaking comments filed with state gaming control boards in 12 states across the study window.

Operators that engaged proactively with state regulators on responsible gambling topics outside of mandatory reporting cycles:

• BetMGM / MGM Resorts (engaged in 9 of 12 states)
• DraftKings (engaged in 8 of 12 states)
• FanDuel (engaged in 7 of 12 states)
• Caesars Sportsbook / Caesars Entertainment (engaged in 6 of 12 states)
• Penn Entertainment (engaged in 4 of 12 states)
• All other operators (engaged in fewer than 3 of 12 states)

“We hear from a small number of operators consistently. We hear from most of them only when there is a specific compliance matter. There is a clear distinction in the relationships.”

— Massachusetts Gaming Commission public meeting, October 2025

That distinction will matter in California, Texas, Florida, Georgia, Minnesota, and Missouri. The operators that have built proactive regulator relationships in mature legal markets enter pre-legalization conversations in new markets with measurable advantages. The operators that have not, do not.

The Five-Point Framework for Closing the Communications Gap

Operators that want to address the findings in this audit should focus on five communications investments. None require the magnitude of capital that the existing $3.9B industry budget assumes for awareness channels. All require communications discipline that the current industry budget does not reward.

1. Disclose responsible gambling investment as a percentage of marketing spend. Annual reports, ESG disclosures, sustainability reports. The number does not need to be large to be useful. It needs to be visible. ESG analysts cannot include what is not disclosed.
2. Build owned-media RG content infrastructure that AI engines can cite. Operator-controlled landing pages, executive bylines, partnership announcements, third-party validations. This is the GEO layer. Without it, AI engines describe an operator’s RG program using third-party content the operator did not commission and cannot edit.
3. Establish executive visibility on RG topics outside of crisis windows. Op-eds in Forbes, Fortune, Fast Company, Inc., Entrepreneur, Adweek, PRWeek, Harvard Business Review. Conference appearances at G2E, ICE, SBC Summit, NCPG conferences. Trade press relationships maintained continuously, not activated reactively.
4. Engage regulators proactively in markets the operator does not yet serve. California, Texas, Florida, Georgia, Minnesota, and Missouri are the highest-priority pre-legalization markets. Communications relationships built 18 months before legalization compound. Communications relationships introduced at the licensing stage do not.
5. Invest in earned media at parity with celebrity partnerships. Moving 3 to 5 percentage points of total marketing budget toward the communications channels documented in this audit — earned media, executive visibility, RG communications, GEO content infrastructure — represents $117M to $195M redirected at industry scale. That reallocation does not register on a quarterly earnings call. It registers in regulatory approvals, ESG ratings, investor presentations, and the AI-generated search results that determine where the next decade of American gambling consumers first encounter these brands.

What Comes Next

The 5W Research Division will publish quarterly updates to the RG Communications Index throughout 2026 and 2027, tracking:

• Operator score changes across the 30 audited operators
• New entrant scoring as additional operators launch in legal markets
• AI Citation Share changes across the five major LLM-powered search engines
• ESG disclosure improvements at publicly traded operators
• State-by-state pre-legalization communications readiness in California, Texas, Florida, Georgia, Minnesota, and Missouri

The 5W Responsible Gambling Communications Audit 2026 is available free at 5wpr.com/research/responsible-gambling-audit-2026.

For research inquiries, methodology questions, or operator-specific scoring discussions, contact the 5W Research Division at [email protected].

About 5W

5W is the AI Communications Firm, building brand authority across the platforms where decisions now happen — ChatGPT, Claude, Perplexity, Gemini, and Google AI Overviews — alongside earned media, digital, and influencer channels. 5W combines public relations, digital marketing, Generative Engine Optimization (GEO), and proprietary AI visibility research, helping clients measure and grow their presence in AI-driven buyer research.

Founded more than 20 years ago, 5W has been recognized as a top U.S. PR agency by O’Dwyer’s, named Agency of the Year in the American Business Awards®, and honored as a Top Place to Work in Communications in 2026 by Ragan. 5W serves clients across B2C sectors including Beauty & Fashion, Consumer Brands, Entertainment, Food & Beverage, Health & Wellness, Travel & Hospitality, Technology, and Nonprofit; B2B specialties including Corporate Communications and Reputation Management; as well as Public Affairs, Crisis Communications, and Digital Marketing, including Social Media, Influencer, Paid Media, GEO, and SEO. 5W was also named to the Digiday WorkLife Employer of the Year list.