Part of our series on ASA rulings relating to children’s appeal in gambling marketing

Treat absolute under‑18 follower numbers as a primary risk indicator

Even low percentages (i.e. <5%) can equate to “significant” numbers in absolute terms when the total audience is large. Obtain, monitor and document under‑18 follower counts per platform for anyone you feature. This total should never exceed 100,000 (and the closer to this figure, the more risk there is) – remember this is not a failsafe threshold but an indicator.

Stress‑test sports talent with a cumulative lens

Along with the type of sport and the sportsperson’s status, consider the number of under‑18 followers in absolute terms, gaming/merchandise, appearances in family programming, and event timing. The presence of these elements means that adult‑orientated sports can still present strong‑appeal risk. Be careful with ‘blurring’ or finding other ways to ‘indicate’ personalities or sports stars. It’s not necessary to see a person’s face to tell who they are.

Pundits are not safe by default

A pundit may be “moderate risk” on paper, but combined with a live league debate, fan imagery and a large under‑18 follower base, the ASA may deem the overall execution as having strong appeal.

Use brand logos with caution

If you must reference a team or event, limit use to a restrained visual or audio identifier. Avoid fan experiences, on‑site footage, repeated logos or other depictions that embed viewers in youth appealing sporting culture. The exemption in the Guidance is not a carte blanche to use club IP it as much as you’d like (even with club permission).

Assume self‑declared age data on social media is insufficient

Where content has any potential strong appeal, place the ad only where under‑18s can be excluded via robust age‑verification (e.g., verified CRM lists, payment/credit‑checked databases). Even as platforms introduce multi-step age verification processes as part of the Online Safety Act 2023. Operators should note that these measures alone cannot be used as a foolproof defence against a strong appeal ruling. Unless there is clear evidence that the verification process excludes under-18s to a KYC level, operators should always assume their ad will be considered for strong appeal.

Document your targeting decisions

If you rely on any audience‑exclusion method, retain evidence of the verification standard. Targeting users aged 25+, channels which are adult orientated, and self-certified age‑gated brand accounts are helpful measures, but they will not rescue content that carries strong appeal to children.

Expect continued proactive scrutiny

The ASA’s Active Ad Monitoring and reliance on Ofcom data point to an increasingly data‑driven enforcement model. Be prepared to evidence your compliance measures with quantifiable audience data and the rationale behind the use of the media channels selected.

Next steps

If you have any questions about the issues raised in these rulings or would like to discuss their relevance to your business, please get in touch.

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