Who: The Advertising Standards Authority (ASA) and RTSB Ltd (Match Bingo)
Where: United Kingdom
When: 5 November 2025
Law stated as at: 4 December 2025
What happened:
An ad for Match Bingo appeared at the start and end of a 442oons animation video on a video-sharing platform featuring Tottenham Hotspur football team (Spurs) and other football-related figures singing a song. Following an opening shot of the Spurs team, there was a five second ad for Match Bingo, where a presenter, in the same animated style, announced, “Spurs win the Europa League, sponsored by Match Bingo – where football meets the thrill of bingo”. A phone, the word “WIN”, a football and a bingo card were displayed alongside the Match Bingo logo and on-screen text stating, “Play along with live sports and you could WIN CASH PRIZES”. The middle section of the video, not under Match Bingo’s control, included a song about Tottenham Hotspur football club, “Glory Glory Tottenham Hotspur”, featuring realistic animations of Premier League footballers, football managers and TV pundits. The closing 22 seconds featured the same Match Bingo presenter urging viewers to “Play Match Bingo during this weekend’s football and win cash prizes. Links below”. The presenter ran upstairs singing “Glory, glory Match Bingo” to the same tune featured in the 442oons editorial content. The final screen showed the presenter with a bag of money next to the Match Bingo logo.
A complaint was raised on the basis that the animation of Premier League footballers appealed to children and that the ad had not been appropriately targeted. The ASA did not uphold the complaint.
The ASA assessed whether Match Bingo’s placement of the ad on a video sharing platform had been “directed at” under-18s. The ASA stated that no medium should be used if more than 25% of its audience is, or is likely to be, under 18. The viewing demographics supplied by the 442oons channel showed that only 6.5% of viewers of the specific video were registered under 18, and that over 90% of the channel’s audience as a whole were 18 or over. Accordingly, the under-18 audience was significantly below the 25% threshold.
The ASA also noted that age-restricted ads on social media platforms should not be targeted solely based on age data, given the risk of younger users misreporting their age, different people sharing the same device and non-logged-in users accessing the content. The ASA therefore considered that marketers should be able to demonstrate that they had taken “adequate steps” to ensure that gambling ads were directed at over 18s. The video was marked “Not Made for Kids”, which reduced the likelihood that it was recommended to children. Match Bingo had obtained channel demographic analytics in advance and relied on the channel’s audience profile to demonstrate that 442oons is adult oriented. The ASA concluded that these measures appropriately limited under-18 exposure to the ad.
Finally, the ASA assessed the content’s likely appeal to under-18s. Although the 442oons video used animated Premier League figures, the ASA considered that the animation style was realistic rather than exaggerated, and the humour within the song was satirical, focusing on interactions between players, managers, owners and pundits, rather than on gameplay, which the ASA considered to have less appeal to a younger audience. The ASA noted that while Premier League football would likely be of appeal to some under-18s, it was also of broad appeal to those aged over 18.
Accordingly, taking into account the media selection (where the under-18 audience was significantly below 25%), the steps taken to direct the ad away from children, and the contextual appeal of the video, the ASA concluded that the ad was not directed at under 18s and therefore did not breach the UK Code of Non-broadcast Advertising and Direct and Promotional Marketing (CAP Code).
Why this matters
This ruling underscores the complexities and grey areas in applying the CAP Code and ASA guidance to gambling marketing communications and other restricted product categories.
The 25% audience threshold
Rule 16.3.12 of the CAP Code, which governs the targeting of gambling advertisements, provides that such ads must not “be directed at those aged below 18 years…through the selection of media or context in which they appear”. Section 16 of the CAP Code on gambling does not specifically reference the 25% threshold applied by the ASA in this ruling.
Other rules in relation to similarly restricted products and services under the CAP Code – for example, electronic cigarettes and alcohol – explicitly state that no medium should be used to advertise such products if more than 25% of its audience is under 18.
Notwithstanding the absence of an express reference in the CAP Code, advertisers should be aware that the 25% rule is applied in relation to gambling ads. ASA guidance clarifies that most gambling ads must not appear in media where over 25% of the audience is under 18, and for a limited category of gambling products (including football pools), where more than 25% of the audience is under 16.
In the context of social media, even if a channel satisfies the 25% threshold, advertisers must ensure that ads do not target under-18s, for example, youth-oriented creative content.
Adequate steps
In this ruling, the ASA considered that marketers should be able to demonstrate that they had taken adequate steps to exclude under-18s. In a recent ruling on Betway Ltd, the ASA conversely determined that a reliance on video sharing platform controls, in a context where under‑18 access and misreported ages are well‑evidenced, did not meet the ASA’s expectation of the highest level of age-exclusion accuracy.
Appeal to children
This Match Bingo ad featured realistic animations in the likeness of current Premier League footballers. In a recent ruling on Dribble Media t/a Midnite, the ASA concluded that imagery depicting Premier League stars was likely to be of strong appeal.
Accordingly, while the complaint against this Match Bingo ad was not upheld, the best risk management approach for marketing teams and gambling operators is to proceed with caution. Marketing communications should still be planned on the assumption that significant measures must be deployed to exclude under 18s from the audience, advertisers should not rely solely on self-verified age data, and to minimise risk recognisable Premier League players and logos should be avoided.
