CAP and BCAP tighten gambling ad rules to protect minors

The Committee of Advertising Practice (CAP) and the Broadcast Committee of Advertising Practice (BCAP) have announced a comprehensive update to their guidance on protecting children and young people from exposure to gambling and lotteries advertising. This revision marks a significant step in ensuring that advertisements do not unduly attract under-18s, reflecting a growing focus on social responsibility and the prevention of gambling-related harm among minors.

Background to the updated advertising standards

In 2022, following an extensive public consultation, CAP and BCAP introduced a major change to their rules. The previous “particular appeal” test — which considered whether an advert was likely to appeal more to under-18s than to adults — was replaced with a stricter “strong appeal” test.

Under this new test, marketing content is prohibited if there is a reasonable possibility that it might strongly attract the attention of individuals under the age of 18, regardless of whether it also appeals to adults. The purpose of this shift was to close loopholes that previously allowed certain forms of content to slip through the regulatory net — especially content connected with sport, popular personalities, and video games.

This change broadened the scope of what regulators could consider inappropriate for gambling marketing, effectively heightening industry accountability and aligning advertising practices with public concern over youth exposure.

Why CAP and BCAP revisited the rules

Three years after the introduction of the “strong appeal” standard, both CAP and BCAP have revisited their guidance. This review was based on several factors: a series of rulings by the Advertising Standards Authority (ASA), feedback from industry stakeholders, and new research into media consumption habits among minors.

The updated guidance reflects lessons learned from practical enforcement and aims to clarify areas where advertisers have sought further interpretation. With social media platforms evolving rapidly and influencers playing a growing role in brand visibility, the committees recognised the need to refine their framework to ensure that it remains relevant and effective.

Key updates introduced in the 2025 guidance

The new guidance introduces several notable clarifications and additions, designed to help advertisers assess risk more precisely and comply with the “strong appeal” test.

Clarification on social media following

One of the most significant updates relates to how regulators assess a personality’s audience appeal. The guidance now includes a practical rule of thumb for determining whether a figure may have strong appeal to under-18s:

“One rule of thumb is that at least a total of 100,000 social media follower accounts registered to people under-18, across social media platforms, is indicative of strong appeal.”

This benchmark is not absolute but serves as an indicator. CAP and BCAP note that the ASA may still judge a personality as having strong appeal even if their under-18 follower count falls below this number, depending on other factors — such as their general popularity among minors or the context in which they appear. Conversely, a personality with over 100,000 under-18 followers might not automatically be deemed of strong appeal if additional evidence suggests their content is adult-oriented.

The committees also stress the importance of geographic relevance, warning advertisers to exercise particular caution when UK-specific data about under-18 audiences is unavailable. This highlights the challenge of assessing global social media metrics in a regulatory environment focused on UK advertising.

Introduction of a new context section

The updated document now includes a Context section, recognising that the appeal of certain content can depend heavily on the setting and the way it is presented. For instance, the same sports personality might appear in two different campaigns — one promoting a responsible gambling initiative and another endorsing a betting platform — yet the level of youth appeal may differ significantly between the two.

By introducing this contextual framework, CAP and BCAP encourage marketers to assess not just who or what appears in an advert, but how it is presented, the tone used, and the likely audience of the media channel in which it appears. This nuanced approach supports a more case-by-case evaluation, balancing creative freedom with child protection.

Clarification on adult-centric and non-adult-centric sports

Another major area of refinement concerns the classification of sports and how they relate to youth appeal. The new guidance provides additional examples and definitions to distinguish between adult-centric sports — such as horse racing, darts, or snooker — and non-adult-centric sports like football, basketball, and eSports, which tend to have large youth followings.

Under this clarification, marketers are advised to avoid using athletes, teams, or imagery from non-adult-centric sports in gambling promotions, as these are more likely to capture the attention of minors. However, if adult-centric sports figures are used, advertisers must still ensure that the overall tone and placement of the advertisement do not inadvertently appeal to younger audiences.

This update is especially important in an era where sports stars frequently cross over into entertainment and social media, blurring the lines between adult and youth audiences.

Enhanced guidance on social media and digital marketing

Given the central role of digital channels in modern advertising, the revised guidance dedicates a more detailed section to social media and influencer marketing. CAP and BCAP acknowledge that social platforms are increasingly used by gambling companies to target adult audiences, but they also represent a high-risk environment for inadvertent youth exposure.

The committees urge marketers to conduct rigorous due diligence on influencers and brand ambassadors before collaboration. They must assess not only follower demographics but also the influencer’s broader public image, past collaborations, and the nature of their typical content.

Additionally, advertisers are reminded that algorithmic targeting cannot always guarantee exclusion of under-18 users, so the creative content itself must remain compliant even if it reaches unintended audiences.

The role of enforcement and industry responsibility

While CAP and BCAP provide the regulatory framework, enforcement largely falls to the Advertising Standards Authority (ASA). The ASA continues to review complaints, investigate breaches, and issue rulings that set precedent for future advertising conduct.

The updated guidance strengthens the ASA’s ability to interpret and enforce the “strong appeal” test consistently. It also reinforces the shared responsibility between gambling operators, marketing agencies, and individual endorsers to prevent underage exposure.

The committees have made it clear that ignorance of an influencer’s demographics or lack of precise analytics will not excuse non-compliance. In effect, advertisers are expected to adopt a precautionary approach — assuming potential risk where data is incomplete or ambiguous.

Industry impact and reactions

Industry observers have generally welcomed the updates as a logical continuation of CAP and BCAP’s commitment to social responsibility. By clarifying grey areas, the new guidance reduces uncertainty for marketers who wish to comply with the rules while maintaining creativity in their campaigns.

However, some operators have expressed concern that the 100,000-follower rule could be difficult to apply in practice, particularly given the limited transparency of social media analytics. Others have warned that overly cautious interpretation might limit the use of public figures who are popular across age groups but not specifically targeted at minors.

Nevertheless, the overarching industry sentiment acknowledges that the reputational and regulatory risks of non-compliance outweigh the marketing advantages of broader celebrity endorsements.

Broader implications for gambling advertising

The updates also form part of a wider effort across the UK to ensure that gambling is conducted in a socially responsible manner. Regulators, including the Gambling Commission, have repeatedly emphasised the importance of reducing gambling-related harm and preventing exposure to vulnerable audiences.

CAP and BCAP’s renewed focus on youth protection aligns with these national objectives, as well as with international trends. Many jurisdictions are now adopting similar standards, recognising that young people are increasingly exposed to gambling-related messaging online, often in subtle or indirect forms.

By tightening the definition of “strong appeal” and clarifying how digital personalities are evaluated, the UK is setting a benchmark for evidence-based, proportionate regulation that balances commercial freedom with child protection.

Looking ahead: the importance of compliance and monitoring

The updated guidance is now in effect and will continue to evolve as new data emerges. CAP and BCAP have indicated that they will monitor the implementation of these rules closely and may issue further clarifications if new technologies or marketing practices present unforeseen risks.

Advertisers are encouraged to review their campaigns, conduct audience assessments, and maintain records of how compliance decisions are made. Doing so not only helps avoid regulatory scrutiny but also demonstrates a company’s commitment to ethical marketing practices.

Ultimately, these updates reinforce the principle that protecting under-18s is not simply a regulatory obligation — it is a cornerstone of responsible gambling advertising and a safeguard for the industry’s long-term credibility.

Conclusion

The latest updates from CAP and BCAP mark a clear reaffirmation of the UK’s commitment to shielding minors from gambling influences. By refining the “strong appeal” test, introducing practical benchmarks, and addressing social media dynamics, the committees have modernised their framework to meet today’s digital challenges.

While compliance may require greater diligence and data-driven assessment, the outcome is a more transparent, responsible, and socially conscious advertising environment — one that prioritises the wellbeing of young audiences and the integrity of the gambling sector as a whole.

FAQs

What is the “strong appeal” test?
It is a stricter standard used by CAP and BCAP to assess whether gambling advertisements might unduly attract under-18s, replacing the earlier “particular appeal” test.

Why was the guidance updated in 2025?
The committees updated the rules to reflect enforcement experience, stakeholder feedback, and new research into how minors engage with digital and sports content.

What does the 100,000 social media follower rule mean?
It serves as a guideline suggesting that personalities with around 100,000 under-18 followers may have strong youth appeal, requiring extra caution in advertising.

Does this rule apply to all influencers?
Yes, but context matters. Even influencers with fewer under-18 followers could still be deemed of strong appeal depending on their image or content.

How does the new context section affect advertisers?
It requires advertisers to consider how setting, tone, and execution influence appeal, not just who appears in the advert.

Are sports advertisements affected by the new rules?
Yes. Ads linked to non-adult-centric sports such as football or eSports face greater scrutiny due to their popularity among under-18s.

What should gambling operators do to comply?
They should conduct due diligence on influencers, assess demographics, avoid youth-focused imagery, and document compliance processes.

How do these changes align with UK gambling policy?
They support broader national objectives to reduce gambling-related harm and promote socially responsible marketing practices.

Will the guidance be reviewed again?
Yes. CAP and BCAP regularly review their standards and may adjust them as media trends and technology evolve.

Why is compliance important for advertisers?
Non-compliance risks ASA sanctions, reputational damage, and potential breaches of licensing conditions, making adherence crucial for all operators.