Responsible marketing content
Five review questions that apply in every market, with the specific rules for Great Britain, Ontario, the US and Europe.
Compliance brief · Compliance
In Great Britain, gambling marketing content must follow the CAP Code, which license condition SR 5.1.6 makes mandatory for Gambling Commission licensees. Operators are responsible for their affiliates. Since January 19, 2026, bonus wagering requirements are capped at 10 times and offers may not mix gambling products.
| Instrument | Status | Applies to |
|---|---|---|
| Gambling Commission LCCP (license conditions) | Conditions attached to licenses under the Gambling Act 2005 | Licensed operators, and through SR 1.1.2, the third parties they contract |
| CAP Code section 16 (non-broadcast) | Self-regulatory code, made mandatory for licensees by LCCP SR 5.1.6 | All gambling marketing, including websites, social media and affiliate content |
| CAP and BCAP guidance | Guidance on how the ASA applies the code | Interpretation, for example of "strong appeal" |
The Commission's license condition SR 5.1.6 says: "All marketing of gambling products and services must be undertaken in a socially responsible manner." Licensees "must comply with the advertising codes of practice issued by the Committee of Advertising Practice (CAP)". For media the codes do not explicitly cover, licensees "should have regard to the principles included in these codes of practice as if they were explicitly covered".
CAP rule 16.3.12 says gambling marketing must not "be likely to be of strong appeal to children or young persons", and must not include "a person or character whose example is likely to be followed by those aged under 18 years or who has a strong appeal to those aged under 18". The strong appeal test replaced the older "particular appeal" test on October 1, 2022.
Rule 16.3.14 adds: "No-one who is, or seems to be, under 25 years old may be featured gambling or playing a significant role." The code allows 18 to 24 year olds only in marketing placed where a bet can be placed directly, such as the operator's own site, and only to illustrate a bet of which they are the subject.
Guidance updated on October 14, 2025 gives a rule of thumb for social media: "at least a total of 100,000 social media follower accounts registered to people under-18" indicates strong appeal. An ASA enforcement notice on social media ads, with active monitoring from June 11, 2026, lists current Premier League footballers (and UK players at top European clubs) and current England players, including AI representations of them, as high-risk content.
For content teams, that means:
Football previews carry most of this risk. The sportsbook editorial calendar guide covers how previews and evergreen pages can stay within the under-18 rules.
LCCP SR 1.1.2 states: "Licensees are responsible for the actions of third parties with whom they contract." Contracts must bind third parties as if "bound by the same licence conditions and subject to the same codes of practice", with termination rights, "including for affiliates where they have breached a relevant advertising code of practice." The ASA has said operators are "at least jointly" responsible for affiliate content. An affiliate article about a welcome offer is therefore operator marketing for compliance purposes.
The Commission's revised SR 5.1.1 requires bonus terms to be "clear, transparent, and fair" and "readily accessible". Licensees must not "Apply wagering requirements ... over a maximum of 10 times" or "Include more than one type of gambling product (betting, casino, bingo, and lottery) within an incentive." The Commission decided this in a consultation response published on March 26, 2025, and the rules took effect on January 19, 2026.
Pages written before 2026 that describe 35 times or 40 times wagering as normal, or combined "bet and get casino spins" offers, now describe offers licensees cannot make in Great Britain. Update or retire them. The Commission has not banned the word "free"; it leaves that to CAP, which requires that offers are not presented misleadingly.
Yes. Affiliate content promoting an operator is marketing, and the ASA holds operators at least jointly responsible for it. License condition SR 1.1.2 also makes operators responsible for the third parties they contract.
Ten times, under license condition SR 5.1.1 as revised with effect from January 19, 2026. The same change banned offers that combine different gambling products.
Only with great care. Current Premier League and England players are flagged as high risk by the ASA because of their appeal to under-18s, and the strong appeal rule applies to all gambling marketing.
Checked October 25, 2026. Rules and documentation change; the official source prevails over this summary.
Corrections. None since publication. Spotted an error? Write to hello@wagerink.online.