ASA ruling against William Hill for same-day “cash match” voucher that risks encouraging irresponsible use

The Advertising Standards Authority (“ASA”) has upheld a complaint against William Hill Organization Ltd (“William Hill”) regarding a promotional voucher that offered a £5 cash match, redeemable only during a limited window later the same day it was issued. The ASA found that the promotion, which required customers to stake at least £50 before qualifying, risked incentivising repeated or prolonged gambling within a short period and breached the UK Code of Non-broadcast Advertising (“CAP Code”) rules on promotional marketing.

Background

On 3 April 2025, William Hill issued automatically printed promotional vouchers to customers on their slot machines stating “You’ve won a £5 cash match on any game!” and “Redeemable between 03/04/2025 – 03/04/2025 from 05:20 PM – 11:59 PM in any venue”. The promotion lasted for three days and was available to customers who had placed a minimum stake of £50 on eligible gaming machines before 5:20pm on the day in question. Redemption was permitted only from 5:20pm onwards on that same day. The £50 stake included the total value of stakes placed in-store that day, including the original cash in and any repeated play of winnings. A complaint was lodged with the ASA challenging the narrow redemption window and whether this was in breach of CAP Code rule 8.5 by encouraging irresponsible use.

William Hill maintained that the promotion was a low-value, one-off reward that did not involve any progressive elements, wagering multipliers, or additional conditions, and therefore was not designed to encourage excessive staking or prolonged play. William Hill explained that the qualifying conditions were displayed on digital screens at the premises, giving customers ample information to decide whether to participate in the promotion, and that the voucher merely restated those conditions. William Hill provided evidential data showing that most eligible customers did not redeem the £5 voucher, and the majority of those who did waited at least three hours before doing so, suggesting they had left the premises in the interim.

William Hill did not believe the staking threshold to be a substantial amount and supported this with evidence that the average cash-in across the three-day promotion was less than the average spend for April and May 2025. William Hill stressed that the £5 cash match reward was modest and that redemption was entirely optional with no encouragement to remain on premises, return later that day, or stake excessively. William Hill further stressed that their in-store staff were trained to identify and act if customers illustrated signs of problem gambling, including repeated visits. 

Decision

The ASA upheld the complaint.

The ASA considered the same-day, post-qualification redemption window to be problematic as most participants could only claim the promotional reward by either remaining in-store or returning the same day. The ASA noted this was reflected in the data of timeframes between vouchers being issued and subsequently redeemed. The ASA’s view was that this created a time-bound incentive and increased the risk of consumers gambling more than they might have otherwise. The ASA also considered that the £50 stake threshold would mean that those eligible for the promotion would likely have already placed a number of bets that day.

The ASA deemed the promotion to be in breach of CAP Code rule 8.5 for encouraging irresponsible use. 

The ASA instructed William Hill to ensure the contested voucher did not appear again and reminded them that future promotions should avoid mechanisms that might encourage irresponsible use.

Comment

This ruling serves as a pointed reminder of the ASA’s ongoing scrutiny of gambling promotions, particularly those that risk incentivising repeated or prolonged play within a compressed timeframe. The decision underscores the ASA’s view that even modest, low-value rewards can cross the line into irresponsible marketing if the mechanics of the offer encourage customers to gamble more than they otherwise would.

The ASA’s assessment focused not on the absolute value of the reward, but on the structure of the promotion, and specifically, the requirement to stake a substantial sum (likely through multiple bets) before a narrow, same-day redemption window. The finding that most eligible customers would need to either remain on the premises or return later the same day to redeem the voucher was central to the ASA’s conclusion that the promotion risked encouraging behaviour contrary to the principles of the CAP Code.

More broadly, the ruling aligns with the ASA’s stepped-up enforcement posture seen in recent decisions involving gambling content.

Co-Authored by Helena Thornby, Trainee Solicitor at CMS