New Strictly hosts confirmed: why gambling operators should be paying attention

The BBC’s confirmation that Emma Willis will join Josh Widdicombe and Johannes Radebe as one of three new Strictly Come Dancing hosts is more than entertainment news for gambling operators. The regulatory interest is that Willis was also the subject of a May 2024 ASA ruling, in which a People’s Postcode Lottery TV ad featuring her was investigated under the “strong appeal” rules and not upheld.

That ruling should not be read as carte blanche because, if a celebrity’s public profile changes materially, the safer regulatory approach is to refresh the evidence-led assessment rather than rely on a historic ruling. Moreover, operators should consider whether they have sufficient contractual and commercial protections in place if a celebrity who is key to their marketing campaign has a material shift in their potential appeal to under-18s.

The original ruling

The ad, seen in November 2023, featured Willis in a dressing room with The Voice logo visible in the mirror and a large “V” on the wall. The issue was whether the ad included someone likely to be of strong appeal to under-18s. Postcode Lottery, relying on the CAP and BCAP “strong appeal” guidance, accepted Willis had presented The Voice Kids, but argued that she was not a children’s TV presenter and that the programme itself was not likely to be of strong appeal to children.

The social media and commercial evidence also supported Postcode Lottery’s position. Willis’ 13- to 17-year-old followers represented 0.7% of her Instagram followers and 0.2% of her Facebook followers, which the ASA considered not significant either as a proportion or in absolute terms. The ASA also noted that Willis’ commercial partnerships with brands such as Gillette Venus, Oral-B, Marks and Spencer and Absolute Collagen were adult-focused.

The ASA accepted that The Voice and The Voice Kids had family-viewing aspects, but gave greater weight to the BARB data and Willis’ role in the programmes. It found that the programmes were proportionally much more popular with audiences aged 55 and above, and that Willis’ presenter role had not made her aspirational or influential to under-18s because the focus was on the contestants and judges.

Why a fresh analysis may be needed

The BBC has now confirmed Willis as part of the new presenting line-up for Strictly Come Dancing 2026, with Willis to preside over the ballroom this autumn. The BBC has also confirmed that the latest series of Strictly attracted an average audience of 7.8 million viewers, with 8.6 million tuning in to the Grand Final. The BBC also has a dedicated CBBC page for Strictly, including quizzes, games, clips and “all things Strictly”, which would be relevant contextual evidence in any renewed assessment.

That does not automatically mean Willis would now be of strong appeal to under-18s. The ASA’s previous reasoning suggests that appearing in family entertainment, even in a prominent Saturday night slot, is not by itself determinative. Any future analysis would still need to consider the actual audience demographics for the programme, the nature of the celebrity’s role, whether they are likely to be viewed in an aspirational or influential way by under-18s, and the celebrity’s wider social media and commercial profile.

The confirmed move to Strictly is therefore a relevant new fact, not a predetermined answer.

The updated guidance

This analysis should also be viewed alongside the updated CAP and BCAP “strong appeal” guidance on gambling and lotteries advertising, published on 14 October 2025.

On the use of celebrities, the guidance states that marketers should assess the roles or activities the person is associated with, the potential for them to be viewed in an aspirational or influential way by under-18s, their profile and following, and the audiences for the roles and activities they are known for. The guidance now states that a total of at least 100,000 social media follower accounts registered to under-18s, across platforms, is indicative of strong appeal, but also caveats that the ASA may reach a different conclusion depending on the overall evidence.

This is why Willis’ confirmed Strictly role is relevant to a fresh assessment, without predetermining the outcome. Even if Willis’ under-18 social media following remained below the 100,000 rule of thumb, the broader context of her role, the audience for the programme, how the operator uses her in the creative, and whether the ad trades on aspects of Strictly could all form part of the analysis.

Practical points for operators to consider

The key learning is not that every celebrity who appears on family entertainment shows must be avoided. The key learning is that the “strong appeal” assessment is not static. An assessment of a personality that was supportable at one point may need to be revisited if the celebrity later takes on a new role, has a viral moment, attracts a different audience, or develops a materially different following.

Operators may therefore want to monitor celebrity and influencer activity throughout the life of a campaign, not just at the point the agreement is signed. The updated guidance recognises that appeal can vary depending on setting and execution, and the ASA’s approach requires marketers to use appropriate sources of data and information to assess likely under-18 appeal.

Where monitoring is undertaken, it should be documented. For a presenter now moving into a programme like Strictly, that may mean obtaining updated social media demographics, reviewing BARB or other audience data, considering the programme’s presence on child-facing BBC channels or pages, and assessing whether the campaign creative itself makes any direct or indirect link to the new role.

From a contract perspective, talent agreements can be drafted so operators have the tools to react quickly if the factual position changes. Those agreements might include notification obligations for new roles, endorsements, social media channels or material changes in audience profile, as well as rights to request updated audience data, suspend or edit marketing materials, and terminate or renegotiate where continued use would create regulatory risk.

This is not just a legal issue; it is a commercial one. If a campaign is built around one celebrity, the cost of taking it down can be significant, particularly where assets have already been cleared, media has been bought, affiliate or social activity has been scheduled, and a replacement campaign has to be shot at short notice. The ASA’s system requires non-compliant ads to be withdrawn or amended, which makes it sensible, at the contracting and campaign-planning stage, to think about who bears the cost and operational risk if the celebrity’s profile changes mid-campaign.

Conclusion

The 2024 Willis ruling remains useful because it shows the ASA applying the “strong appeal” test by reference to evidence, not assumptions. The ASA accepted that The Voice and The Voice Kids had broad family appeal, but did not consider Willis’ role in those programmes, her social media demographics, or her adult-focused commercial partnerships to make her of strong appeal to under-18s.

But it is not a standing approval. Now that the Strictly role has been confirmed, any future campaign would call for fresh audience, social media and contextual evidence. Operators should ensure they build monitoring and exit mechanics into celebrity-led campaigns before a profile change forces a rushed takedown, re-edit or reshoot.