UK Regulators Update Guidance on Gambling Ads Aimed at Under-18s
The Committee of Advertising Practice (CAP) and BCAP have issued new guidance to help gambling and lottery advertisers avoid content likely to attract children and teens.
LISTEN TO THIS ARTICLE:The refresh follows a series of Advertising Standards Authority (ASA) rulings and industry feedback after a stricter test for youth appeal was introduced in 2022.
Under the revised approach, the long-standing threshold of whether material has a “particular” appeal to under‑18s was replaced with a tougher “strong” appeal standard in 2022. The new guidance, released this month, explains how that higher bar should be interpreted in practice and provides practical indicators advertisers can use when assessing campaigns, talent partnerships and social content.
One of the more concrete additions is a social media rule of thumb: if a personality’s combined follower accounts that are registered to under‑18s across platforms total around 100,000, this is indicative of a likely “strong” appeal to under‑18s. The CAP and BCAP emphasize that this figure is a guide rather than a rigid threshold – the ASA may still judge content to have strong youth appeal below that number, or conversely find no strong appeal above it, depending on context, creative execution and audience composition. The guidance also stresses the difficulty of assessment where UK‑specific audience data is absent and urges marketers to proceed cautiously.
The new guidance adds a Context section clarifying that the same creative can have different appeal depending on how and where it appears. It also explains the distinction between “adult‑centric” and “non‑adult‑centric” sports – the former being sports with little evidence of significant participation or viewership among under‑18s – and how that classification should influence the permissibility of gambling or lottery references in marketing.
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The ASA has recently stepped up enforcement activity, particularly around social media and influencer posts. In the past three years, many of the Code breaches involved posts by athletes, former professionals or gaming personalities, prompting questions about how to assess celebrity and influencer appeal to young people.
Separately, the CAP has moved to close a loophole that previously excluded certain overseas operators from the Code’s reach. As of September 1, the CAP clarified that non‑paid marketing communications aimed at UK consumers by advertisers who are subject to licensing conditions must comply with the CAP Code even if the advertiser does not have a UK‑registered company address.
Recent ASA decisions illustrate how the rules are being applied. Complaints were upheld against advertising for an overseas sports betting operator shown on a virtual football site that attracted a teenage complainant, and against social posts for a sports betting app that the ASA found encouraged irresponsible gambling and excessive drinking. In those cases, the regulator ordered the material removed and set out why it breached the rules.
For operators, agencies and rights holders, the updated guidance raises several practical implications. Brands – including UK online casinos and licensed betting operators – should reassess influencer and athlete partnerships, obtain robust audience data (ideally UK‑specific), and factor in placement and context when planning creative. Sports organizations and broadcasters that use talent and social channels to promote sponsors will need clearer contracts and compliance checks to avoid inadvertent breaches.
Industry trade groups and compliance teams are likely to revisit approval workflows, invest in audience measurement tools and increase legal scrutiny of shot lists and edits for broadcast and social assets. The ASA retains powers to require the removal of content and to publish rulings that can damage reputation, so proactive risk management will be essential.
While the guidance provides practical markers for compliance, its flexibility – particularly around the 100,000 follower rule of thumb – means that judgments will remain fact‑sensitive. Advertisers operating in the UK market should treat the update as both a warning and a prompt to tighten controls around how gambling and lottery messages reach younger audiences.
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