SBC News

William Hill has been reprimanded by the Advertising Standards Authority (ASA) over a promotional voucher that was deemed to possibly encourage irresponsible play.

The ASA’s report stated that a customer received a voucher from a slot machine in a William Hill betting shop on 3 April 2025 at 11:51am. The voucher had the following text:

“You’ve won a £5 cash match on any game!”

“Redeemable between 03/04/2025 – 03/04/2025 from 05:20 PM – 11:59 PM in any venue”.

Within a complaint to the ASA, it was challenged whether the timeframe between the voucher being received and when it could be redeemed was a breach of the CAP code since it was “socially undesirable by encouraging irresponsible use”.

Despite William Hill arguing that the voucher didn’t breach the code or encourage socially undesirable or irresponsible behaviour, the ASA upheld the complaint and told the operator that the ad must not appear again in its current form and that future promotions must not encourage irresponsible behaviour.

William Hill: voucher not ‘designed to drive repeated play’

The voucher was issued to customers who deposit £50 or more on an eligible gaming machine before 5:20pm on the day that the promotion is issued and valid. This figure is the total value placed in-store, including a customer’s original cash-in and subsequent winnings played again.

Evidence was provided by William Hill to the ASA that the average cash-in in relation to the three-day promotion was “below the average spend for April and May 2025”. Therefore, the operator felt the amount that must be spent “to qualify for the promotion was substantial, nor that the promotion encouraged excessive staking”.

As it was a £5 voucher and could be spent on any game, the operator believed the promotion was “a low-value, one-off reward” and didn’t “involve any progressive elements, wagering multipliers, or additional conditions beyond what was initially displayed”.

William Hill noted it was “not part of a broader incentive structure nor designed to drive repeated play”, adding that the promotion’s terms, including the staking threshold and the redemption timeframe, were “clearly and fully” communicated to customers, and they were “given sufficient information to make an informed decision before participating”.

In addition, key qualifying conditions were “displayed on digital promotional screens in the shop and the voucher reiterated those eligibility conditions”, with the voucher serving as a “confirmation of eligibility which reminded consumers of the pre-disclosed redemption timeframe”.

William Hill also argued that the voucher’s redemption was entirely optional and that customers were free to not redeem the voucher or return later the same day. The operator supplied data too, showing that most customers who qualified for the voucher didn’t redeem it, which they believed demonstrated that customers knew redemption was optional.

The operator described the £5 voucher as ‘modest’ value and “did not believe that at any stage the promotion encouraged a customer to remain on the premises to engage in excessive consumption, nor encouraged irresponsible use”.

Although the promotion began at a later time than when the voucher was awarded, William Hill stated that it “did not encourage participants to remain on the premises and therefore it did not create any time-sensitive pressure to continue playing”, adding that very few customers redeemed the voucher within two hours, with most waiting three hours.

The operator said that the extended time between the voucher being issued and redeemed “strongly indicated” that most customers left and returned later to redeem the voucher, undermining the suggestion that the redemption window “pressured customers to remain in-shop or extend their play”.

William Hill added that any concerns regarding customer behaviour would have been met with a response in line with their polices, as all staff in their shops have received training to identify signs of gambling-related harm, and gaming machines provide prompts to remind customers of their time and money spent and allow customers to set limits.

ASA calls voucher ‘irresponsible’

Acknowledging the operator’s point of view, the ASA has upheld the complaint against William Hill since the timeframe of when the voucher is issued and redeemable “created an incentive for repeated play within a short period, including visiting the betting shop twice in a single day, increasing the risk of consumers gambling more than they otherwise would”.

Since the redemption period was at a later point in the day, the authority noted that participants could only benefit if they returned to the premises or stayed until the start time of the promotion, and that those eligible for the voucher may have already placed several bets earlier the same day.

“We thus considered that linking the reward to a same-day timeframe, particularly at a limited period later on the day, incentivised behaviours that could encourage irresponsible use,” the ASA stated.

“For those reasons, we concluded that the promotion encouraged irresponsible use and breached the Code”, particularly CAP Code (Edition 12) rule 8.5 (Protection of consumers, safety and suitability).

William Hill was told by the ASA that the advert must not appear again in the form complained of and that future promotions must not encourage irresponsible behaviour.

The UK Gambling Commission’s (UKGC) full attention remains on fighting the black market, the regulator’s CEO, Andrew Rhodes, has reaffirmed.

In a speech at the International Association of Gaming Regulators (IAGR) in Toronto, Rhodes made sure to highlight the UKGC’s continuous efforts to hit back at black market operators through a dedicated team created three-and-a-half years ago.

“We make sure there are penalties and disincentives for being in the illegal market, but also one of our obligations under the Gambling Act, which created us as an organisation is we are here to protect children and the vulnerable from being exploited by gambling,” Rhodes said.

Part of the Commission’s targeted campaign against unlicensed operators includes the disruption of online traffic through a close collaboration with search engines.

Rhodes added that he expects the UKGC to report a total of 200,000 URLs by the end of this financial year. As a result, there’s already been “nearly 100,000” blocked websites.

“We’re tracking over 1000 illegal operators as we try to shut them down… if we can remove things from search results, we make it harder to find, so we slow them down.”

Black market still in the spotlight
Despite the UKGC’s efforts, there is an interesting phenomenon going on in the UK where gambling brands that are typically unlicensed to operate are striking high profile sponsorship deals with sports clubs, particularly in the Premier League.

This led to a huge outcry earlier this year when TGP Europe was forced to leave the UK market and cease its white-label operations managing Asia-facing brands like DEBET and bj88 – partners of Wolverhampton Wanderers FC and AFC Bournemouth respectively.

Just last week, Leicester City announced that BC.GAME, another unlicensed operator, will continue to be the club’s principal partner through the 2025/26 season. All these instances are widely viewed as counter-intuitive to what the UKGC is aiming to achieve.

Potential tax hike could complicate things
On top of that, the next budget coming in on 26 November could potentially raise the tax rates for the gambling sector – with the UK Treasury looking at several options on the table.

One of which would be to align all three existing tax systems with the current Remote Gaming Duty (RGD) at 21%, which would impact the retail betting sector the hardest given that the levy there is currently at 15%.

However, another option being discussed is to raise the RGD rate from 21% to 50%, which would undoubtedly cast a huge shadow on the revenues of licensed online gambling operators. This might inadvertently impact the end user cost, leading to more black market migration.

Rhodes addressed taxation during his speech in Toronto, saying: “Now these are going to be really big debates and they’re taking place in many countries at the moment, and it is quite hard sometimes when different factors change to work out exactly what impact each individual component had.

“That’s why in GB, we’ve got an evaluation programme, which is to evaluate the impact, as best we possibly can of the different changes that the Gambling Act Review White Paper has delivered within our country.”

A Sky Bet ad featuring Gary Neville has placed the effectiveness of the Advertising Standards Authority’s (ASA) new guidance under the microscope.

The ASA has upheld its challenge that a promoted post on X by Sky Bet featuring an embedded video clip from the Overlap football podcast was likely to be of strong appeal to those under 18 years of age because of the presence of Neville. The decision was made in spite of Neville having retired from the game in 2011.

As a result, the ASA found that Bonne Terre Ltd, which trades as Sky Bet, had breached the advertising rules which all UK-licensed operators must follow.

Weighing up the risks

In reaching its decision, the ASA used new guidance released by the Committee of Advertising Practice (CAP) and the Broadcast Committee of Advertising Practice (BCAP), which considers that an influencer followed by over 100,000 social media accounts registered to people under-18 is “indicative of strong appeal”.

According to the ASA, when the ad was posted in February 2023, 5% of Neville’s 1.6 million Instagram followers were registered as under 18, which amounts to 80,000. Additionally, 1% of his 5.5 million X followers were registered as under 18, bringing his under-18 following on the two platforms to approximately 135,000.

The ASA could not garner the same data for under-18 followers on TikTok and Facebook, but noted that the former Manchester United right back had 963,400 and 42,395 followers on the platforms, respectively.

Although the new guidance has set the follower threshold at 100,000, it also clarifies that the ASA can deem a personality to be of strong appeal if they fall under that figure, or not of strong appeal even if they have more than 100,000 under-18 followers.

Given this case-by-case basis approach to regulating marketing, Sky Bet argued that Neville did not hold strong appeal to under-18s.

In the clip posted on X, Neville is seen participating in a fan debate on the Overlap podcast discussing which team would win the Premier League in that year. During the clip, Sky Bet’s logo appeared intermittently and at the end stated “brought to you by Sky Bet”, and the BeGambleAware logo appeared.

According to the ruling, Sky Bet stated that 1.2% of the Overlap’s audience was aged 13-17 years, and that figure dropped to 0.5% for the advertised episode.

The operator also noted that Neville ended his playing career in 2011 and fell into the category of “long retired”, which on its own would place the eight-time Premier League winner as low-risk of appealing to under-18s according to the CAP code.

Alongside the Overlap, Neville also works as a TV pundit on Premier League broadcasts and for England’s international matches. The ASA stated that, in this context only, this would place him in the “moderate risk” category of the guidance.

However, the ASA’s decision hinged on the demographics of his social media followers.

The ruling stated: “We considered that over 135,000 social media follower accounts registered to people under-18 was a significant number in absolute terms, with the true total figure potentially higher due to the absence of data for the other social media platforms.

“Although we accepted that his career as a football pundit and his media profile in isolation would have placed him within the ‘moderate risk’ category, we considered that a large number of social media follower accounts that were registered to under-18s and followed Neville indicated that the inclusion of Neville in an ad would make it of strong appeal to under-18s.”

Setting a precedent?

Although the ASA recognised that X had protection policies for under-18 users in 2023 and the ad was set to target over-25s with a stated interest in sport, it also noted that the platform relies on users self-verifying their age upon sign-up.

Like in a previous ruling against Midnite, it cited research from Ofcom that found 32% of eight to 17-year-olds with at least one social media account had a registered user age of 18 or above.

As a result, the ASA considered it likely that a significant number of children who had not used their real date of birth when signing up to X could see and be promoted to content from verified gambling accounts.

The ASA also addressed the issue of duplicate social media followers. While accepting that it is likely some individuals would follow the same person across different social media platforms, the ASA considered follower counts “a strong indication of that personality’s appeal and level of popularity”.

“In the absence of data indicating that duplication significantly reduced the follower count for a personality, we considered that advertisers should err on the side of assuming that all were individual followers,” the ruling continued.

Sky Bet were warned that the ad must not appear in its current form on social media again, and told not to include a person or character with a strong appeal to those under-18 in future advertising.

ASA accelerating action

Sky Bet was not the only operator to fall foul of the ASA in its latest set of rulings.

Eaton Gate Gaming Ltd, which trades as Kwiff, was similarly reprimanded for a post on Kwiff’s X account which featured Sir Lewis Hamilton.

The post in question featured text stating “A potentially huge weekend for Sir Lewis Hamilton ahead of the British Grand Prix at Silverstone [race car emoji] #F1”. The post contained an image of Sir Lewis Hamilton and a banner across the bottom that featured an 18+ symbol and the BeGambleAware.org logo.

Kwiff argued that the post followed CAP guidance, which stated that “motorsports and golf are more adult-oriented and unlikely to be of inherent ‘strong appeal”, and cited a 2022 report that found the median age of F1 fans was 32 and the majority were 25-44.

Kwiff also highlighted that its X page had 11,700 followers, and 0% of those were aged 13-17.

Given that the post was published the day before the 2024 British Grand Prix, which Hamilton won, the ASA ruled that the purpose of the communication was to promote Kwiff’s brand and gambling services, therefore, it fell under the scope of the CAP Code.

The ASA assessed that Hamilton’s “exceptional success” in his sport, social media presence and long-standing career place him as a household name in the UK.

CAP guidance states that sportspeople involved in clearly adult-oriented sports who are ‘notable stars’ with significant social media and general profiles which made them well known to under-18s were likely to be of ‘moderate risk’ of strong appeal to under-18s.

In the case of Hamilton, 4% of his 37.5 million followers on Instagram, approximately 1.5 million, were under 18 years of age.

This alone places him way above the 100,000 threshold, even before numbers from any other platforms are considered, and the ASA deemed him likely to have a strong appeal to under-18s.

“We acknowledged that Sir Lewis Hamilton was primarily famous for his association with an adult-oriented sport, but considered he was very well known to a general UK audience, including to children and young people. We considered, based on his public profile, commercial partnerships, media appearances and UK under-18 social media following, that he had strong appeal to under-18s,” the ruling concluded.

Betway Ltd was also reprimanded for airing a pre-roll YouTube advert that featured football fans wearing clothes and scarves with the Chelsea FC logo.

The ASA upheld a complaint that argued featuring the Chelsea logo would likely be of strong appeal to under-18s, and therefore breached the advertising code.

Under the CAP Code, football is deemed an activity of inherent strong appeal to under-18s.

Although the ASA noted that using the club logo in a standalone context would have been acceptable, showing it on fans’ scarves, lanyards and hats in the context of a stadium experience was likely to be of strong appeal to children and young people who supported Chelsea or followed football more widely.

Like with X, the ASA also cited YouTube’s age verification policy, which relies on users to self-report their age upon sign-up.

“Because YouTube was a media environment where users self-verified on customer sign-up and did not use robust age-verification, we considered that Betway had not excluded under-18s from the audience with the highest level of accuracy required for gambling ads where their content was likely to appeal strongly to under-18s,” the ruling explained.

Betway had argued that a brand lift survey showed that the ad campaign had resulted in an 8% increase in brand awareness, all of which was from YouTube users aged 55 and over.

The operator also stated that it had not included any active football play, wide shots of Chelsea’s Stamford Bridge stadium or extended views of the pitch to reduce the ad’s connection with football.

Both Kwiff and Betway were informed that their respective ads must not appear in their current form and warned against including people or characters who had a strong appeal to those under 18 years of age.