Key Moments:
- The UK Advertising Standards Authority (ASA) has set a new threshold for influencers. Those with over 100,000 under-18 followers may now be seen as having “strong appeal” to minors.
- ASA’s revised rules focus on context, not just follower counts. They emphasize content style and cultural references that may attract young audiences.
- Recent rulings involved Ladbrokes and Midnite, highlighting evolving interpretations of “strong appeal” and increased regulatory scrutiny on advertising content.
Clarification and Complexity Around Social Media Influencers
The latest guidance from the UK Advertising Standards Authority (ASA), issued through CAP and BCAP, strengthens protections for under-18s from gambling marketing. One key change sets a clear benchmark. Influencers with over 100,000 followers who are minors may now be considered to have “strong appeal” to these audiences. One key change sets a clear benchmark. Influencers with over 100,000 followers who are minors may now be considered to have “strong appeal” to these audiences.
This development compels marketers to exercise careful judgment before partnering with personalities for gambling campaigns. The ASA has provided case examples to assist in applying the rules – for instance, while a lower-league footballer may appear to present minimal risk, an audience that skews heavily under 18 could still make an advert non-compliant under the new framework.
Expanded Focus on Ad Tone, Themes, and Presentation
The ASA’s update goes beyond audience demographics by expanding its rules on the stylistic and thematic elements of gambling advertisements. Marketers are now advised to avoid visuals, fashion, music, and social signals targeting younger audiences. The guidance also cautions against depictions of teenage rebellion, disrespect for authority, and cultural cues rooted in youth media, such as gaming and streaming cultures.
The regulatory authority considered figures from sports such as cricket, tennis, and rugby as generally low-risk, while elite footballers and esports stars are classified as highly influential among under-18s. These changes represent the first major revision since 2022, when the “strong appeal” benchmark replaced the older “particular appeal” standard.
Regulatory Actions and Recent Decisions
Recent decisions by the ASA signal its commitment to more actively policing youth-targeted gambling marketing. In June 2025, Ladbrokes encountered complaints about advertisements featuring “Ladbucks,” a free-to-play currency that the ASA determined could resemble popular virtual currencies like Fortnite’s V-Bucks and Roblox’s Robux, potentially appealing to minors.
Additionally, Midnite was instructed to remove an AI-generated video advertisement that included footballer Trent Alexander-Arnold. Although the post was described as editorial content, the ASA ruled it fell within the CAP Code. The regulator stated that professional footballers “are likely to appeal strongly to children and young persons.”
These rulings underscore the evolving definition of “strong appeal” and the complexities operators face in balancing innovation with regulatory expectations.
Operational Impact for Gambling Businesses
Licensed gambling operators must comply with the stricter CAP and BCAP standards in order to hold approval from the UK Gambling Commission. The new guidance requires brands to conduct more rigorous assessments and due diligence when selecting influencers, athletes, or content creators for promotional purposes. The ASA clarified that the rule changes followed a policy process involving research, industry feedback, and the review of recent enforcement cases.
While the updates aim to clarify compliance obligations, the ASA acknowledged that many decisions will still require judgment based on the overall context of individual campaigns. For gambling firms, the current environment means that engaging digital audiences without breaching the “strong appeal” rule is an ongoing challenge, raising important questions about the future of marketing creativity within the bounds of tighter advertising regulations.
| Influencer Follower Count | ASA Classification | Example Figures |
|---|---|---|
| Over 100,000 under-18 followers | Potential “strong appeal” to minors | Elite footballers, esports stars |
| Below 100,000 under-18 followers | Assessment depends on context | Lower-league athletes, smaller influencers |
| N/A | Generally low risk | Cricket, tennis, rugby players |
- Author
Daniel Williams
