Who: The Advertising Standards Authority (ASA), Mecca Bingo Ltd, Buzz Group Ltd and Play’n GO Malta Ltd
Where: United Kingdom
When: July 2025
Law stated as at: 17 August 2025
What happened:
The ASA was busy in July investigating three different gambling operators due to complaints that their adverts had undue appeal to children.
Firstly, an ad on Buzz Bingo Grimsby’s social media page (seen on 12 April 2025) featured a cartoon figure of a woman in a box labelled “[NAME] ACTION FIGURE”. The box also contained a bingo dabber, bingo cards and a numbered ball. A caption on the post stated, “For a limited time only Buzz Bingo Action Figures [crying laughing face emoji] Only available at Buzz Bingo Grimsby! [eyes emoji] T&Cs Apply […] Player Together [sic], Safely […] Over 18s Only” and included a link to gambleaware.org. Two complainants argued that the advert was of strong appeal to children.
Buzz Group disputed the claim saying that it was its general manager in the shot and that it was following a social media trend. It also argued that its social media page is restricted to those that self-identify as over 18. It also argued that the cartoon figure appeared in plain office clothing and was not smiling.
The ASA decided not to uphold this complaint since the overall style of the ad was realistic, rather than cartoon-like. The figure depicted was an adult who did not have exaggerated features, was wearing a simple shirt and was not a recognisable or well-known character – as such, the advert did not appeal to children to the level required to uphold the complaint.
Next, Mecca Bingo’s social media post in May 2025 advertised a puzzle game, stating “NAME THE TOM HANKS FILMS”. It was accompanied by a series of 32 emojis, that had to be deciphered to name the relevant film. The emojis included, among other things, a teddy bear, a child’s face, a mermaid and a rocket. The complainant challenged whether the ad was likely to appeal strongly to children because of the use of emojis.
Mecca Bingo argued that Tom Hanks and his films would not directly appeal to children and that the sole purpose of using emojis was to provide clues to decipher the actor’s films. It also provided demographic data from its social media account which showed that its audience was predominantly over 25, with only 2.9% of followers in the 18 to 24 age bracket.
The ASA considered that the emojis had a cartoon-like appearance and that some emojis used would hold interest for children, such as the teddy bear, the mermaid, and the rocket, as well as various depictions of sport, including a football. However, those emojis were no more prominent than the others, which included the Italian flag, an SOS sign and a briefcase. Of 32 emojis in total, the vast majority depicted everyday objects or symbols. The claim was therefore not upheld.
Finally, Play’n GO Malta Ltd was investigated for three adverts featuring: a cartoon Easter bunny in a superhero outfit; a cartoon robot DJ with a purple screen for a face; and three anime-style, cartoon princesses. Play’n GO Malta argued that the adverts were for three specific separate slot games based on the depictions in the adverts. While it acknowledged that the imagery could be of interest to children, it argued that the actual slot machine being advertised would not, meaning that the overall ad would not appeal to children. It also argued that it had strong controls in place to prevent an under-18 from viewing the ads.
The ASA upheld this ruling, finding that the imagery used clearly strongly appealed to children. While it would have been acceptable for such ads to appear on a platform to which under-18s were entirely excluded through the use of robust age verification measures, the measures deployed by the platform on which Play’n GO’s ads appeared, which consisted of users self-declaring their age, were not sufficiently robust to ensure that children were excluded.
Why this matters:
This set of rulings continues the intense scrutiny by the ASA of businesses in the gambling sector. If businesses are able to prove to the ASA that their ads do not appeal to children, for example with evidence that certain emojis or celebrities are not of appeal, then the ASA has shown it will consider such evidence and not uphold complaints in those circumstances. However, where the defence is that children may not see the adverts because of the controls in place, this is likely to fail if the ads are of inherent appeal to children.
