UK LEGAL
CARTOONS
More recently, the ASA has adjudicated on a few adverts featuring cartoons, emojis and animated characters.
Play’n GO ran three banner ads in April 2025, which featured (respectively) the easter bunny in a superhero outfit, a cartoon robot DJ and anime-style cartoon princesses. The ASA considered that all of these characters were of strong appeal to under 18s, so these adverts should not be repeated. Although Play’no GO as a B2B provider does not provide casino games directly to consumers, the adverts were nonetheless considered “likely to have the effect of promoting gambling” so subject to the rules.
In contrast, a cartoon image of the General Manager of Buzz Bingo Grimsby was deemed acceptable for use on Buzz Bingo’s Facebook page. Although it used an “action figure” style which was thought might appeal to some under 18s, the ASA considered that the overall style of the advert was realistic rather than cartoon-like, and that children were unlikely to view this action figure as an appealing toy to play with.
A Santa emoji appeared in a Facebook advert for
MrQ.com in December 2023, along with an image of a cartoon Santa driving a snow plough. The ASA took the view that Christmas and the traditions surrounding it were likely to have strong appeal to children, with Santa being particularly high risk. Christmas themed adverts were also considered in the Peter Crouch decision mentioned earlier, however in that case there was no particular Christmas theme that would appeal to children, such as a depiction of Santa. We can infer that other Christmas characters, such as a reindeer or snowman, would also be higher risk, whereas more general Christmas scenes such as a snowy landscape or festive décor are likely to be acceptable.
In May 2025, Mecca Bingo made a Facebook post inviting viewers to decipher the name of 10 Tom Hanks films from a series of emojis. The advert did not include any image of Tom Hanks himself, so the ASA did not comment on whether he would be of strong appeal to under 18s, however a complainant objected to the use of emojis which they felt were of strong appeal to children. 32 emojis were used in the advert in total, including some which represented objects associated with children’s interests such as a teddy bear, mermaid and football. However, the ASA considered that these particular emojis were no more prominent than others used in the quiz, such as an Italian flag and briefcase. Overall, the ASA did not consider that this advert was likely to have strong appeal to under 18s. An advert that features emojis where most of them relate to children’s toys and youth culture is more likely to be in breach of the rules.
24 SEPTEMBER 2025
TARGETING EXCEPTION A key exception to the strong appeal rule is that an advert may include content that is of strong appeal to under 18s, if under 18s are effectively excluded from the audience. Play’n GO’s banner adverts were seen by complaints next to a child’s email inbox. Whilst Play’n GO had used targeting measures through Adroll, these measures relied on website cookies which ensured users were only served the banners if they had opted into receiving gambling adverts. This meant that a child using their parent’s device or the same IP address, for example, might be served the adverts. Although adverts were not intentionally served to under 18s, in order to take advantage of the strong appeal exemption it is necessary that adverts are only served to those who have been age verified. Likewise, when it comes to advertising on social media platforms, advertisers must only use content which strongly appeals to under 18s if the audience has been robustly age- verified. The ASA confirmed this in its ruling against Ladbrokes’ use of Premier League footballers mentioned above, where Twitter users had only self-verified their age on sign up and this age gating was deemed to be insufficient. In some cases Meta has recently begun to require users to provide ID to verify
their date of birth, so it’s possible that in the future operators could advertise content of strong appeal to targeted users in compliance with the ASA’s rules.
PRACTICAL TAKEAWAYS Any advertising for gambling products that features sports personalities, cartoons, or anything else that might be associated with children or youth culture, should be considered carefully before use in any context where viewers have not been robustly age verified. For sports personalities, the initial consideration is whether they are currently playing at a high level in a sport popular with children. If this are not, they may be acceptable for use, but their total count of followers aged under 18 across social media platforms should be considered. Beyond that, their appearance in other contexts such as television shows may also be relevant. When it comes to cartoon imagery, it’s more difficult to make an objective assessment but a common-sense approach to whether the character is likely to appeal to under 18s should be taken. Characters in children’s cartoons, cute characters (particularly animals) and others popular with children, such as Santa and the Easter Bunny, should all be avoided.
Melanie has been providing UK legal and regulatory advice to betting and gaming clients since the advent of the Gambling Act 2005. She advises on all aspects of gambling law including licence applications, compliance, advertising, licence reviews and changes of control and is described in the legal directories as “a very impressive lawyer” who “demonstrates commercial pragmatism supported with a great deal of technical and operational knowledge and experience”.
Melanie has acted for a wide range of gambling operators including major online and land-based bookmakers and casinos, B2B game and software suppliers and start-ups. She also frequently advises operators of raffles, prize competitions, free draws and social gaming products. Melanie has a particular interest in the use of new technology for gambling products and
novel product ideas. She is a regular contributor to industry publications and often speaks at industry events. Melanie is listed as a ‘Leading Partner’ in the Legal 500 guide and is also ranked in Chambers.
Page 1 |
Page 2 |
Page 3 |
Page 4 |
Page 5 |
Page 6 |
Page 7 |
Page 8 |
Page 9 |
Page 10 |
Page 11 |
Page 12 |
Page 13 |
Page 14 |
Page 15 |
Page 16 |
Page 17 |
Page 18 |
Page 19 |
Page 20 |
Page 21 |
Page 22 |
Page 23 |
Page 24 |
Page 25 |
Page 26 |
Page 27 |
Page 28 |
Page 29 |
Page 30 |
Page 31 |
Page 32 |
Page 33 |
Page 34 |
Page 35 |
Page 36 |
Page 37 |
Page 38 |
Page 39 |
Page 40 |
Page 41 |
Page 42 |
Page 43 |
Page 44 |
Page 45 |
Page 46 |
Page 47 |
Page 48 |
Page 49 |
Page 50 |
Page 51 |
Page 52 |
Page 53 |
Page 54 |
Page 55 |
Page 56 |
Page 57 |
Page 58 |
Page 59 |
Page 60 |
Page 61 |
Page 62 |
Page 63 |
Page 64 |
Page 65 |
Page 66 |
Page 67 |
Page 68 |
Page 69 |
Page 70 |
Page 71 |
Page 72 |
Page 73 |
Page 74 |
Page 75 |
Page 76 |
Page 77 |
Page 78 |
Page 79 |
Page 80 |
Page 81 |
Page 82 |
Page 83 |
Page 84 |
Page 85 |
Page 86 |
Page 87 |
Page 88 |
Page 89 |
Page 90 |
Page 91 |
Page 92 |
Page 93 |
Page 94 |
Page 95 |
Page 96 |
Page 97 |
Page 98 |
Page 99 |
Page 100 |
Page 101 |
Page 102 |
Page 103 |
Page 104 |
Page 105 |
Page 106 |
Page 107 |
Page 108
