Note: This advice is given by the CAP Executive about non-broadcast advertising. It does not constitute legal advice. It does not bind CAP, CAP advisory panels or the Advertising Standards Authority.
Free bets and bonuses are popular promotional tools in the gambling sector, for example free spins on casino games and free bets for new customers. As well as complying with the rules in Section 16: Gambling, the promotional marketing section of the Code (Section 8) will also apply.
Advertisers should avoid promotions and ads that are misleading or unclear.
Include significant terms and conditions
Make full terms easily accessible
Ensure all promotions are responsible
Be clear and accurate
Ads that include promotions should ensure that the offers are clear and accurate to avoid being considered as misleading. Marketers should not describe an offer as “free” if the customer must risk their own money to qualify. Ambiguous terms like “risk-free” should also be avoided, unless the customer genuinely cannot lose their own funds.
Include significant terms and conditions
Under CAP Code rule 8.17, all marketing communications or materials referring to promotions must clearly and prominently communicate all applicable significant conditions if their omission is likely to mislead consumers. This information must be clear and upfront. Rule 8.17 lists some conditions which are likely to be considered significant in all types of promotional marketing. Here are some examples that are likely to be considered significant in ads for gambling promotions –
- Eligibility restrictions (e.g., new customers only, age, location).
- Deposit or wagering requirements.
- Time limits for claiming or using the offer.
- Minimum odds or bet types.
In 2024 the ASA investigated a promotion for a free £10 bet, after the customer could not take advantage of the offer. In order to qualify for the free bet, consumers had to reply to a text message by a certain time, however, this was not stipulated in the ad. The ASA considered this was a significant condition and the omission was likely to mislead, (GB Sports Advisors Ltd t/a Geoff Banks Online, 17 July 2024).
The ASA investigated a ‘voucher’ offered by an advertiser in 2025. The voucher for a £5 free bet was not valid on 14 March due to the Cheltenham Gold Cup, however this was not specified on the voucher at all. The ASA considered this was a significant condition about how to participate in the promotion and so breached the Code (SP Graham Retail Ltd, 27 August 2025)
Make full terms easily accessible
As well as including the significant terms and conditions in the ad, the full terms and conditions for the promotion should be easily accessible. For online ads, full terms and conditions should be usually be one click away from the main ad. Also the links must be clear and prominent, not hidden in footers or small print.
In 2024 the ASA investigated a complaint about a promotion and a payment method that was excluded. The ad included this information in small print further down the page, among the full terms and conditions. The ASA considered the excluded payments information was a significant condition of the promotion, and although it was not omitted entirely from the ad, its position meant that it was easy for consumers to overlook it and was therefore insufficiently prominent (WHG (International) Ltd t/a William Hill Online, 31 July 2024).
Avoid misleading omissions
Ads should make clear any conditions that consumers need to partake in any offer. Omitting key information could affect a consumer’s understanding of the offer, for example if a “free bet” requires a qualifying bet, this must be stated clearly.
Ensure all promotions are responsible
As well as the rules above, ads for promotions must comply with all the rules in Section 16 of the Code, which applies to ads for gambling products. Ads must not strongly appeal to under-18s and should not target under-18s or appear in media where they form a significant proportion of the audience.
Promotions should also be responsible and ensure that they do not encourage repetitive or frequent participation. Ads should not trivialise gambling and should avoid the impression that the decision to gamble should be taken lightly.
Advertisers should exercise caution when encouraging people to take advantage of a promotion, and should not encourage people to spend more than can afford to lose. These positions are explained in further detail in our advertising guidance on ‘responsibility and problem gambling’.
See also: Promotional marketing: General, Promotional marketing: terms and conditions and significant conditions and Gambling, betting and gaming: General