Ad description

The mobile home page for an online gambling site, Butlers Bingo,, seen on 15 April 2016. The web page featured the promotion "Deposit £10. Play £35".


The complainant challenged whether the ad was misleading as it failed to make clear that a wagering requirement applied before consumers could withdraw their winnings.


Broadway Gaming Ltd t/a apologised and said that the omission of information about the wagering requirements had been an oversight. They said that they had now updated the mobile home page to include a prominent qualification “terms, conditions and wagering requirements apply” and a link to the terms and conditions in the footer of the ad. They said there was also a link to the terms and conditions on the registration page when a user signed up through the home page.



The ASA considered that, in the absence of information to indicate otherwise, consumers were unlikely to understand from the offer "Deposit £10. Play £35" that, after they had wagered the initial £25 bonus, they would be required to wager further money before they could withdraw earnings from their accounts.

We noted, however, that users were not able to withdraw from their accounts until they met further wagering requirements. Those were calculated at five times the bonus funds received on a customer's first deposit for bingo games, and 50 times the bonus funds received for slot games and certain casino games; wagers on several casino games such as Roulette, Blackjack and Video Poker did not count towards the wagering requirement. For example, if the customer solely played bingo, they would first have to wager £125 before they could withdraw money from their account and for all other eligible games they would have to wager at least £1,250.

We noted that those requirements had been outlined in the website's terms and conditions. However, we considered that the wagering requirement was a significant condition which was likely to influence a consumer's decision of whether or not to take up the offer, and therefore should have been made clear to consumers in the main body of the ad. Consequently, while we welcomed the advertiser's amendment to the ad, we considered that it was not sufficient, and concluded that the omission of the wagering requirements from the ad was likely to have misled consumers.

The ad breached CAP Code (Edition 12) rules  8.17 8.17 All marketing communications or other material referring to promotions must communicate all applicable significant conditions or information where the omission of such conditions or information is likely to mislead. Significant conditions or information may, depending on the circumstances, include:  and  8.17.1 8.17.1 How to participate
How to participate, including significant conditions and costs, and other major factors reasonably likely to influence consumers' decision or understanding about the promotion
 (Significant conditions for promotions).


The ad must not appear again in its current form. We told Broadway Gaming Ltd to ensure that their ads included the wagering requirements for promotions where their omission was likely to mislead.

CAP Code (Edition 12)

8.17     8.17.1    

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