Authors
Introduction
On 29 July 2026, the Advertising Standards Authority (“ASA”) challenged an ad for a BoyleSports promotion which offered customers escalating rewards, including free bets and a share of a £10,000 weekly jackpot, based on how many days they placed ‘qualifying’ bets. The ASA concluded that the promotion encouraged frequent and repetitive gambling behaviour and could lead to financial harm, contrary to the CAP Code. The ruling forms part of a broader ASA review of gambling advertising.
Background
The ruling concerned a paid-for advertisement that appeared on the Racing Post website in March 2026 promoting BoyleSports’ “Bank Builder Jackpot”. The offer was structured around the number of days on which a customer placed a qualifying £10 bet during a promotional week. Depending on the number of qualifying days, customers could receive free bets and, at the highest level of participation, entry into a share of a £10,000 weekly prize pool.
The ASA investigated whether the promotion crossed the line from presenting an offer to encouraging gambling behaviour that was socially irresponsible or had the potential to cause financial harm.
Decision
Under the CAP Code, gambling advertisements must not portray, condone or encourage gambling behaviour that is socially irresponsible or likely to lead to financial harm. In addition, CAP guidance states that advertisers should avoid encouraging frequent or repetitive participation in gambling activities.
BoyleSports argued that the promotion was designed to appeal to customers with different levels of betting activity and did not require customers to participate every day or throughout the full promotional period. Customers could qualify for rewards after betting on any four days within a week, those days did not need to be consecutive, and customers were not required to opt in to a challenge or complete every stage of the offer. BoyleSports also emphasised that the qualifying stake was capped at £10, so customers could not increase their rewards by staking more. It characterised the ad as largely informational, clearly setting out the qualifying criteria and reward structure without using pressure-selling tactics, countdown mechanisms or messaging that suggested gambling was a route to financial success. In support of that position, BoyleSports relied on customer data which it said showed that most participants did not aim for the highest tier and that the offer had not led to a material uplift in betting activity.
The ASA accepted that daily participation was not an express requirement. However, its assessment focused on how the promotion operated in practice. The entry point for any reward still required qualifying bets on four separate days in a single week, with progressively greater rewards available only where customers bet on five, six or all seven days. On that basis, the ASA considered that the promotion created an incentive to gamble on the majority of days in the week.
The ASA was particularly concerned by the way the headline rewards were unlocked. The “up to £60 in free bets” element depended on qualifying activity on six days a week across the four-week promotional period. Participation in the weekly £10,000 prize pool required the most intensive level of engagement: a qualifying bet on every day of the relevant week. Even though customers were free to stop short of those tiers, the ASA considered that the presentation of rewards such as “SHARE OF £10K EVERY WEEK” was capable of encouraging sustained, repeated betting.
The timing of the free bet rewards also contributed to the ASA’s decision. Rewards earned in one week were intended to be used soon afterwards, and some Cheltenham Festival free bets expired only shortly after being credited. The ASA considered that this short redemption window risked extending betting activity beyond the initial qualifying period and reinforcing a cycle of repeated gambling.
Comment
The ruling highlights the need for operators to consider their promotional mechanics carefully. Loyalty programmes, reward schemes and “bet club” promotions may appear relatively low risk, particularly where participation is voluntary and rewards are modest, however the mechanics of a promotion may still incentivise customers to gamble more frequently or repeatedly than they otherwise would. Escalating reward structures linked to repeated betting activity, particularly where customers are incentivised to participate across multiple days or weeks, are likely to attract regulatory attention.
Co-authored by Lucy Igbiri, Trainee Solicitor