ASA upholds complaint against Betway Ltd for advert featuring Chelsea FC branding with strong appeal to under-18s

Introduction  

On 22 October 2025, the Advertising Standards Authority (“ASA”) upheld a complaint against Betway Ltd (“Betway”) about a pre-roll advert that it published on a video sharing platform (the “advert”). The ASA found that the advert, which included several references to the Chelsea FC logo (the “logo”) on clothing and scarves, was considered to have “strong appeal” to under-18s and therefore breached the UK Code of Non-broadcast Advertising (“CAP Code”).

Background

On 17 May 2025, Betway posted an advert on a video sharing platform which featured football fans wearing clothing and scarves with the Chelsea FC logo. The advert promoted Betway’s rewards scheme and showcased elements of a stadium tour.

One complaint was made against the advert, challenging whether it breached CAP Code 16.3.12 by featuring the Chelsea FC logo, making the advert likely to be of strong appeal to under-18s.

Betway argued that its use of the logo complied with B/CAP Guidance. Whilst the guidance acknowledges that football has an inherently strong appeal to under-18s, Betway noted that it permits gambling ads to include content that “specifically identifies a subject of the gambling activity,” such as a sports team logo, to balance protecting under-18s with advertisers’ rights to promote licensed products. Betway maintained that its rewards scheme was an integral part of the gambling activity and that the logo functioned as a permitted identifier, similar to an audio or visual reference. 

Betway also noted efforts to reduce the advert’s football association by avoiding any active play, wide stadium shots, or extended pitch views. Additionally, the featured individuals were adult competition winners, so their clothing choices were incidental. Betway submitted that the advert was targeted at logged-in users of the video sharing platform who were aged 25+ with relevant interests, in line with the Industry Group for Responsible Gambling requirements.

The Ruling – Did the advert breach the CAP Code?

The CAP Code prohibits gambling advertisements that are likely to be of strong appeal to under-18s, particularly by reflecting or being associated with youth culture. B/CAP Guidance identifies football as an activity of inherent strong appeal to under-18s which would fall under the prohibition, unless appropriate steps are taken to limit the potential for the ad to appeal strongly to under-18s. Furthermore, marketers are permitted to include content which specifically identified a subject of the gambling activity, for example, the logo of a sports team.

The ASA considered it would have been acceptable for the logo to appear in a standalone context, for instance at the end of the advert, where it would act as a visual reference to a subject of the gambling activity but noted in this case that the logo was also shown on fans’ scarves, lanyards and hats as well as on team shirts on wall displays and backdrops within the stadium building. Due to the depiction of the logo in an advert that showed a stadium experience for fans, the ASA noted that this was likely to strongly appeal to children and young people who supported Chelsea FC or followed football more widely and that its appearance in this context went beyond any permitted exemption for identifying content and therefore was likely to be of strong appeal to under-18s.

Additionally, the ASA considered it would be acceptable for the advert to appear in a medium where under-18s, for all intents and purposes, could be entirely excluded from the audience, for example in circumstances where those who saw the advert had been robustly age-verified as being 18 or older, such as through marketing lists that had been validated by payment data or credit checking. However, as the video sharing platform was a media environment where users self-verified when signing up, and did not use robust age-verification, the ASA considered that Betway had not excluded under-18s from the audience with the highest level of accuracy required for gambling adverts where their content was likely to appeal strongly to under-18s.

Ofcom research cited by the ASA indicated that a significant number of under-18s who had social media used the video sharing platform, and of that amount, a measurable number had profiles registered with an age of at least 18. Consequently, the ASA considered that there was at least a significant number of children who had not used their real date of birth when signing up to the video sharing platform and were able to see and access content intended for those aged 18 or older, meaning they could view advertising content from gambling operators.

The ASA concluded the advert breached CAP Code rules 16.1, 16.3 and 16.3.12. Betway was instructed not to use the advert again in its current form and reminded to avoid content with strong under-18 appeal in future gambling marketing.

Comment

This ruling reinforces the ASA’s strict approach to gambling ads, featuring sports-related content. Following recent case law, it reiterates the ASA’s process when assessing whether an advertisement is of “strong appeal” to under-18s, and the precautions operators must take when using content that is inherently attractive to under-18s, even if no direct inducement is present in the ads and clear mitigating steps are taken to reduce the attraction to under-18s. 

Moreover, it enforces that a key consideration of the ASA for related matters where the advert may have content of strong appeal to under-18s is the necessity for targeting controls to be robust and demonstrably effective in excluding under-18s. An operator’s reliance on self-verification of the age of under-18s is very unlikely to be sufficient for satisfying the exemption.

Therefore, operators should carefully assess the use of sports-related content in marketing and ensure that any “high-risk” branding is excluded unless under-18s can be completely excluded from the audience. This ruling serves as a reminder that even indirect promotional content – particularly when linked to high-risk branding – may fall within the ASA’s remit and attract enforcement action.

Co-Authored by Oyin Olukotun, Trainee Solicitor at CMS