CAP and BCAP strengthen under-18 protections for gambling and lotteries advertising

The question

What changes have CAP and BCAP made in their updated guidance on protecting under-18s from gambling and lotteries advertising?

The key takeaway

CAP and BCAP have updated their 2022 guidance to provide clearer, more detailed expectations for assessing when gambling or lottery ads carry a “strong appeal” to under-18s. The revised Guidance places greater emphasis on social-media influence, sports associations, follower demographics, and contextual factors. Marketers must now undertake a more rigorous assessment to ensure that ads do not inadvertently target or appeal to minors.

The background

In 2022, CAP replaced the previous “particular appeal” test with the stricter “strong appeal” standard, prohibiting content that is likely to resonate powerfully with under-18s regardless of adult appeal. Following two years of enforcement experience, stakeholder feedback and new research, CAP has issued updated Guidance to help advertisers understand how modern trends - particularly social-media culture and sport - influence youth appeal.

The update aims to clarify risk categories, address evolving online behaviours, and provide practical tools for compliance.

The development

The Guidance now begins with a practical checklist to help advertisers identify and mitigate strong-appeal risks. Key updates include:

1. Reinforced “black-letter” rules: Advertisers must continue to comply with strict prohibitions, including:

• no featuring individuals aged under 25 in gambling or lottery ads (subject to narrow exceptions); and
• the 25% audience threshold, ensuring ads are not targeted at media where under-18s comprise more than 25% of the audience.

2. Updated high-risk content indicators: CAP highlights content types that are particularly likely to appeal strongly to under-18s, including:

• animations, cartoon styles and video-game-inspired graphics,
• youth-culture references, memes or influencer-driven trends, and
• themes or aesthetics common to games popular among under-18s.

3. Clearer categories of inherently high-appeal activities: Certain activities are treated as high risk by default, including:

• football (especially top-tier UK clubs and national teams),
• eSports,
• scratchcards, and
• online games with mechanics or characters attractive to younger audiences.

Where these are referenced at all, advertisers must limit references to generic, low-appeal depictions.

4. Refined casting guidance and risk tiers: The Guidance significantly expands the rules relating to individuals featured in ads, dividing them into risk categories:

• High-risk: leading eSports players; children’s TV or film personalities; individuals with a substantial under-18 social-media following; UK top-tier or national-team footballers; and sportspeople associated with sports popular among under-18s.
• Moderate-risk: mid-tier footballers, retired footballers now in punditry (depending on profile), lower-profile international footballers, and sportspeople in adult-centric sports who nonetheless have wide youth recognition.
• Low-risk: non-league or lower-league footballers, long-retired players with minimal public profile, and sportspeople involved in sports with negligible under-18 participation.

5. Social-media influence and follower demographics: CAP introduces a 100,000 under-18 follower benchmark across platforms as an indicator of strong youth appeal. This is not determinative:

• a personality may still be considered high-risk with fewer followers, and
• a personality with more than 100,000 under-18 followers may be permitted if contextual factors show low appeal.

CAP also warns that actual under-18 follower numbers are likely to be higher due to mis-reported ages and that UK-specific follower data is often limited.

6. Contextual factors and media placement: The “strong appeal” rules do not apply where advertisers can essentially guarantee under-18s will not be exposed to the ad (e.g., certain strictly age-gated media). Situational context - including tone, visuals and placement - remains critical.

Why is this important?

The updated Guidance reflects the fast-evolving influence of social media and sport on youth audiences. It significantly narrows the scope for compliant gambling and lottery advertising by:

• expanding categories considered inherently risky,
• raising expectations around evidence gathering (including follower demographics), and
• emphasising contextual and presentation-driven risks.

Marketers must demonstrate a robust, well-documented assessment of youth appeal for every campaign. Ads featuring popular personalities, sports associations or online-culture references are now more likely to face scrutiny - and removal - if they risk engaging under-18s.

Any practical tips?

• Carry out thorough audience analysis for any personality featured in ads, paying close attention to follower demographics, platform insights and emerging viral trends.
• Maintain comprehensive audit trails, including justification for casting and content decisions, to support compliance if challenged by the ASA.
• Assess situational context - music, tone, visual style and placement - not just the individuals featured.
• Review ads regularly after publication, as personalities can quickly gain youth appeal due to viral moments.
• Treat the Guidance as a risk framework, not a checklist: individual cases will always depend on the ad's overall impression.

Winter 2025