Most Operators Have Not Disclosed the Number.
Three institutional ESG research desks have begun including responsible gambling investment as a percentage of total marketing spend in published research notes covering publicly traded U.S. gambling operators, according to a 24-month industry audit released by the 5W Research Division.
The ratio is appearing in Sustainalytics gambling sector reports, MSCI ESG Ratings methodology updates for the consumer services sector, and ISS ESG corporate rating reviews for publicly traded gambling operators, according to the audit. The reports cover Flutter Entertainment, MGM Resorts International, and Caesars Entertainment, among other publicly traded operators.
The figure that has triggered the analyst attention: across the U.S. sports betting, online casino, and land-based gambling industries, operators spent an estimated $520 million on celebrity and athlete endorsement partnerships in 2025 against an estimated $60 million on responsible gambling programs and communications, a ratio of 8.7 to 1, the highest of any regulated American consumer category with a public-health dimension.
What the audit measured
The audit, titled the 5W Responsible Gambling Communications Audit 2026, reviewed 30 operators across three segments, drawing on 47,000-plus earned media articles, 180-plus ESG disclosures and 10-K filings, 240-plus state regulator filings and testimony transcripts, and 2,400-plus AI engine queries across ChatGPT, Claude, Perplexity, Gemini, and Google AI Overviews. The study window ran from May 1, 2024 to April 30, 2026.
The 5W Responsible Gambling Communications Index scored 30 U.S.-facing operators on 100 points across five buckets: disclosure quality, program depth, earned media proof, executive visibility, and AI answer-engine retrievability. The method captures what a Sustainalytics analyst, a state gaming-control-board reviewer, and a ChatGPT retrieval pipeline each read when asked the same question: what is this operator doing on responsibility, and where is the evidence?
Of the 12 publicly traded U.S. gambling operators reviewed, only four disclose responsible gambling investment as a percentage of marketing spend in annual reports or ESG disclosures. The remaining eight disclose dollar figures only, or do not break out the line item. The audit notes that the gap limits ESG analyst visibility into how operators are weighting responsible gambling against advertising channels.
Three regulated categories, three ratios already crossed
The audit places the 8.7-to-1 ratio against three comparable regulated categories with public-health exposure. U.S. tobacco settled at roughly 1.5-to-1 within five years of the 1998 Master Settlement Agreement between 46 state attorneys general and the four largest U.S. tobacco companies. U.S. alcohol runs around 4-to-1, held by voluntary industry codes. U.S. pharmaceuticals run close to 1-to-1 under FDA prescription drug advertising rules that carve fair-balance risk communication into every 30-second spot. None of those three reached its band voluntarily. All three were forced there, by litigation, by federal mandate, or by industry codes written under threat of both. The full historical comparison, including how each prior industry crossed the ratio threshold, is covered in EPR's companion piece "Tobacco Got to 1.5:1 in Five Years. Gambling Is at 8.7:1."
Gambling is at 8.7-to-1. No publicly traded U.S. operator surveyed has issued a specific defense in investor communications. That silence is what moves the number from the marketing file to the ESG file.
The RG Communications Index leaderboard
Top performers: MGM Resorts International (81/100), BetMGM Sportsbook (78/100), BetMGM Casino (74/100), DraftKings (71/100), FanDuel (66/100). Each of those operators built the retrievable infrastructure the Index rewards, BetMGM through its GameSense partnership library, FanDuel through Play Well and its Youth Coalition on Sports Betting response, DraftKings through the responsibility push that reshaped its performance-branding strategy in 2024.
Bottom performers: Las Vegas Sands (41/100), ESPN Bet (38/100), Fanatics Sportsbook (34/100), bet365 (29/100), Stake.us (22/100). Each is running acquisition without the corresponding responsibility infrastructure. In ESG terms, that reads as a management gap. In state-regulator terms, missing evidence of operational intent. In AI-engine terms, invisibility on the responsibility queries that increasingly gate buyer discovery. For the operator-level deep dive on each score, what drives the 59-point spread, what the Index does and does not measure, and what operators in the bottom half can do, see EPR's full breakdown: The RG Communications Index 2026: MGM Leads at 81. Stake.us Anchors at 22.
Finding one: the ESG disclosure gap
Non-disclosure is not neutral inside Sustainalytics methodology, it is a management-gap input into the underlying ESG Risk Rating and feeds the controversy score that governs index-level ESG fund inclusion. MSCI ESG Research and ISS ESG use parallel structures. All three refresh quarterly or on rolling controversy triggers.
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's sovereign wealth fund), the California State Teachers' Retirement System, the Church of England Pensions Board, PGGM, ABP, and Ontario Teachers' Pension Plan. A one-notch ESG downgrade of a mid-cap operator in a regulated category has historically widened credit spreads by 15 to 25 basis points and triggered forced selling from ESG-mandated index funds.
Finding two: regulator asymmetry
In the 38 U.S. states where sports betting is currently legal, only 11 have state regulators that receive proactive responsibility-program communications from operators more than once a year. Fewer than three operators per year, per state, engage regulators outside of licensing renewals or crisis windows. The remainder communicate reactively, after enforcement action, after a complaint, after a headline.
The mirror finding, the Pre-Legalization Penalty: in Michigan, Ohio, and North Carolina, operators that published responsibility content in-market before legalization received measurably faster regulatory approval than operators that entered cold. The Michigan Gaming Control Board, the Ohio Casino Control Commission, and the North Carolina State Lottery Commission all read pre-legal responsibility content as evidence of operational intent. California, Texas, Florida, Georgia, and Minnesota are next. Missouri passed sports betting in November 2024. The operators publishing in those markets now are building regulatory equity that compounds.
Finding three: the AI Citation Gap
Prompt ChatGPT with "which sportsbook has the strongest responsible gambling program" and the engine names BetMGM in 78% of responses and DraftKings in 64%. FanDuel, market leader by gross gaming revenue, appears meaningfully less. Six other major operators appear in fewer than 20% of responses. The pattern holds across Claude, Perplexity, Gemini, and Google AI Overviews with variation at the margins.
The engines are not ranking by paid spend. They retrieve from indexed responsibility content, third-party earned media, state-regulator .gov domains, and Reddit, where r/sportsbook, r/gambling, and r/problemgambling now rank operators in real time. Since the OpenAI-Reddit indexing deal in May 2024, that signal flows directly into ChatGPT responses. Operators that earned Reddit credibility through service, cash-out reliability, and dispute resolution win the AI citation. Operators that fought Reddit lose it.
What happens next
Three cycles pick up the number first. ESG rating firms refresh scoring quarterly, with controversy triggers driving ad-hoc revisions inside 90 days. State legislative testimony picks up the 8.7-to-1 headline as a talking point, the National Council on Problem Gambling and the Responsible Online Gaming Association now have a citable third-party audit to hand committee members in California, Texas, Florida, Georgia, and Minnesota. Q4 2026 earnings calls will be the first cycle where sell-side analysts read the number back to CEOs on the record.
The reallocation math the audit recommends: three to five percentage points of the marketing base shifted toward earned media at parity with celebrity partnerships. At a $3.9 billion 2025 U.S. gambling marketing base, that is $117 million to $195 million redirected, the price of the ESG shelf, the state-regulator shelf, and the AI answer shelf, all at once.
5W founder and chairman Ronn Torossian, who has published commentary on the audit's implications, frames the ratio as a cost-of-capital metric now priced by Sustainalytics, MSCI, and ISS, tracked by institutional allocators, and material to Q4 earnings, and argues separately that the AI citation leaderboard is a distinct discovery-layer restructuring operators cannot close with more television spend. The audit's authors note that the report measures communications and disclosure practices, not the operational quality of operator responsible gambling programs.
The reference resource
The full audit is available at 5wpr.com/research/responsible-gambling-audit-2026. The 5W Research Division has indicated it will publish quarterly updates to the RG Communications Index throughout 2026 and 2027.
