ASA rules on influencers with “strong appeal” to under-18s

The question

When is an influencer considered to have “strong appeal” to under-18s in relation to marketing?

The key takeaway

Whilst influencers and marketing agencies may present demographic data to show that the majority of their followers are over the age of 18, extra care must be taken to consider the personal branding and appeal of influencer to under-18s. This is especially the case in the context of age restricted ads which are presented on social media platforms and which push content to non-followers.

The background

On 24 September 2025, the ASA upheld a ruling against alcohol brand Au Vodka Ltd for three different social media ads. These ads were posted by social media influencers including Lucinda Strafford, who rose to fame from her appearance on Love Island Season 7 (and has featured on subsequent Love Island spin off series) and Kai Cenat, an American Twitch streamer.

In Ms Strafford’s case, the 25-year-old posted an ad of an Au Vodka vending machine being delivered to her house, and trying one of the drinks saying: “That is so good.”. The accompanying text on the TikTok post read “an actual DREAM OMG [hearts emoji] [peach emoji] unlimited Juicy Peach cans [smiling face with tears emoji] & I can keep it?! @Au Vodka ad”.

A complaint was made against Ms Stafford’s ad in relation to whether it was inappropriately targeted at people under 18 years of age.

The development

The ASA upheld the complaint against Au Vodka and found it was a breach of CAP Code (Edition 12), rule 18.15. Whilst Ms Strafford is over the age of 25, and therefore able to feature in an alcohol ad, the ASA ruled that the ad was directed at people under 18 years of age.

Ms Strafford’s management had provided evidence to show that over half of her followers were over the age of 18. However, the ASA observed that the ad was on TikTok, a platform which pushes content to users’ “FYP” (“For You Page”) using an algorithm that presents content from accounts that users may not follow. The content that is pushed by the algorithm is based on what the app believes is of interest to users. Of particular importance was that Au Vodka had acknowledged that 16 to 34 year olds have a particular interest in the Love Island show, and therefore, Ms Strafford’s content was likely to be pushed to the FYP of under 18s.

Whilst other platforms have tools to prohibit under 18s from viewing age restricted ads, the ASA found that TikTok’s platform does not offer tools to accommodate or target such ads - meaning under-18s could not actually be excluded from viewing the ad and therefore, if interested in Love Island, an under-18 may subsequently be presented with the ad from Ms Strafford.

Why is this important?

The ASA’s decision highlights the importance of considering the general branding and appeal as well as follower-demographic of social media influencers when used by brands to advertise age-restricted products. Whilst influencers may be able to present follower demographic data to show compliance with the requirement of no more than 25% of their audience to be under 18, the ASA will look at the general branding and appeal of the influencer, as well as how social media platforms present the advertising to non-followers. Therefore, when using platforms which promote content to non-followers and/or cannot accurately target users by age, brands must be extremely cautious.

Any practical tips?

On 25 September, the CAP published guidance on age-restricted ads which provides useful tips for responsible ad targeting. This follows on from the research the ASA published in March this year into the “strong appeal” of personalities in advertising. The question of when an influencer or personality may be “strong appealing” to under-18s is a difficult and subjective one. However, the ASA study includes a survey of 1,687 people aged 11 – 17 years, which provides useful insight into what the ASA may consider when deciding whether certain influencers have a strong appeal to under-18s.

Autumn 2025