ASA upholds complaint against gambling affiliate for irresponsibly targeted paid search ad

Introduction

The Advertising Standards Authority (“ASA”) has upheld a complaint against Smart Gravity Ltd trading as top10onlinecasinoreviews.co.uk (“Smart Gravity”) after a paid search ad promoting online casino comparison content was served to a consumer who had searched for “help with gambling”. The ruling, published on 9 September 2026, found that the advertisement breached CAP Code (Edition 12) rule 1.3 on social responsibility, on the basis that it had not been responsibly targeted.

Background

A paid-for search ad for top10onlinecasinoreviews.co.uk was seen by an individual on 18 June 2026 when searching for “help with gambling”. The advertisement stated: “UK’s Top 10 Casino Sites – 10 Best Casino Online Sites UK […] Compare The Best Online Slots Sites In The UK 2026. Fast Signups & Mega Bonuses To Claim. The Only Casino List Compiled Of Real Users Ratings! Signup & Enjoy Our Brilliant Offers”. 

A complaint was made on the basis that the ad had been irresponsibly targeted.

In response, Smart Gravity said that it operates as an affiliate comparison website providing reviews and information relating to operators licensed by the UK Gambling Commission and does not, itself, provide gambling services. 

Smart Gravity stated that its campaigns targeted adults in the United Kingdom and that it had established a compliance framework involving regular audits of campaign settings, ongoing updates to its list of excluded search terms, and internal monitoring procedures. It provided its negative keyword list, which had been designed to prevent ads from appearing in searches connected to problem gambling, safer gambling resources, and gambling-related harm. Smart Gravity explained that its advertising strategy used a combination of Exact Match, Phrase Match and Broad Match keywords, and that it had not identified any search queries containing the phrase “help with gambling” matched to its targeted keywords.  Furthermore, they made the point that they have no commercial interest in advertising to individuals seeking support for gambling related harm.

Decision

The ASA upheld the complaint. In doing so, it found Smart Gravity to be in breach of CAP Code 1.3 which requires that marketing communications are prepared with a sense of responsibility to consumers and to society.  

It considered that a user entering the search term “help with gambling” was most likely looking for support, guidance, or resources relating to gambling-related harm, and that such users were likely to include vulnerable individuals seeking to limit their interaction with gambling content. In that context, it found that an ad promoting casino websites offering “Fast Signups” and “Mega Bonuses” was inappropriate for that search query.

The ASA acknowledged that Smart Gravity operated an affiliate comparison website rather than a gambling service itself but found that the ad had the effect of promoting online casino and gambling sites. Because the CAP Code required ads for gambling to have particular regard to protecting vulnerable persons from harm or exploitation, it expected marketers placing ads for gambling-related services to have “very robust controls” in place to prevent inappropriate targeting, given the significant potential for harm to vulnerable users. 

Although Smart Gravity maintained a negative keyword list, the ASA noted that its use of broader keyword matching settings meant that advertisements could appear in response to searches that were thematically related to—but did not exactly match—targeted keywords. It concluded that those broader settings undermined the effectiveness of the negative keyword safeguards, which were insufficient to prevent the advertisement from reaching potentially vulnerable consumers.

Comment

The decision is notable as an ad’s compliance was assessed by reference to the search query used to trigger it and the keyword targeting controls the advertiser had implemented.  

It serves to remind advertisers and gambling operators of the importance of implementing robust targeting controls to prevent ads reaching vulnerable audiences.  In particular, affiliates and operators should carefully consider their keyword search advertising strategy, noting the ASA’s comments here on broader keyword matching undermining the effectiveness of a negative keyword list.

Negative keyword lists should be regularly expanded to cover not only obvious terms relating to gambling addiction and harm, but also broader phrases associated with help-seeking, treatment, and gambling reduction. 

The Smart Gravity decision confirms that the ASA’s expectations regarding responsible targeting extends to affiliate businesses, not only to gambling operators themselves. Smart Gravity does not hold a gambling licence and does not itself provide gambling services; it operates a comparison and review website. Nevertheless, the ASA found that its ad had the effect of promoting gambling services and applied the same standard of social responsibility that would apply to an operator’s own advertising. 

Operators should also be alert to the risk that the search advertising practices of their affiliate partners may result in the operator as well as the affiliate being subject to regulatory scrutiny.  Operators would be well advised to satisfy themselves that their affiliate partners also have adequate controls in place. 

Co-authored by Saphia Kumar, trainee solicitor.