Background
This ruling replaces that published on 11 June 2025. The decision has been reversed, making the complaint Not Upheld.
Two issues were investigated, both of which were Not upheld.
Ad description
A TV ad and a Video on Demand (VOD) ad for Ladbrokes:
a. The TV ad, seen on 17 December 2024, featured a voice-over that stated, “This is a Ladbuck, the new way to get rewarded at Ladbrokes, and these are some of the 100 million Ladbucks that will be dropping weekly. Collect them on our free to play games and choose rewards like free spins, free bets and more. Over 100 million Ladbucks dropping every single week. Plus you can even use them to play your favourite games for free in our Ladbucks Arcade. Like Fishin Frenzy and Goldstrike. Start collecting at Ladbrokes.com”. The ad featured imagery of coins that displayed the initials ‘Lb’, as well as text that stated, “100m LADBUCKS”, “FREE BETS” and “FREE SPINS”.
b. The VOD ad, seen on Channel 4 on Demand on 23 December 2024, was the same as ad (a).
Issue
Two complainants who believed the term ‘Ladbucks’ was likely to be of strong appeal to those under 18 years of age, challenged whether:
- ad (a) breached the BCAP Code; and
- ad (b) breached the CAP Code.
Response
1 & 2.
LC International Ltd t/a Ladbrokes said both ads promoted “Ladbucks”, which was their adult-only rewards programme. Ladbucks were tokens, depicted as red, translucent coins featuring the initials “Lb”, styled in line with the Ladbrokes brand. Consumers collected them for free by participating in selected promotions and could redeem them for limited-time offers within the Ladbucks Store or the Ladbucks Arcade. They could only be used by logged-in, age-verified users over 18. The tokens could not be purchased, had no monetary or exchange value, and expired monthly if not used. Ladbrokes said that, unlike in-game currencies, Ladbucks could not be universally used across all products on their website.
Ladbrokes explained that the term Ladbucks was a play on the Ladbrokes brand name and used the word bucks to signal value within the site. They said bucks was a well-known colloquialism for dollars or money across various contexts, including video games, but was not specific to youth culture and did not have strong inherent appeal to under-18s. They believed the term was not associated with the in-game currencies used in popular online games like Fortnite or Roblox. They said V-Bucks and Robux had to be bought before they could be used to purchase in-game items, and that the only similarity between those currencies and Ladbucks was the use of the word bucks.
They had reviewed the rewards programme in its entirety and said there was no realistic risk that Ladbucks would be linked to Fortnite, Roblox or their associated currencies, V-Bucks and Robux. Ladbrokes believed there was nothing in the imagery or content of the ads that shared similarities with those games. They also said that the visual presentation of the tokens further distinguished them from in-game currencies. V-Bucks were solid, glowed and futuristic in style, while Robux was not a coin. It was hexagonal with no lettering and a distinct colour scheme. They said the Ladbuck design had no stylistic overlap with gaming coins, and that coins and tokens were common in a range of adult-facing industries including gambling and retail loyalty schemes. They highlighted that within the gambling industry, tokens and poker chips were a longstanding feature that created a tangible link to gameplay. They provided examples of branded tokens and online currency designs to support their view that the Ladbucks imagery was not child-oriented and was unlikely to appeal strongly to under-18s.
Ladbrokes added that the ads did not feature bright colours, cartoon-style visuals, fantasy elements, characters, or humour. They said the games mentioned in the ads, such as Fishin’ Frenzy and Goldstrike, were gambling titles aimed at adults. They believed the overall tone, visual style and voice-over were in line with typical gambling advertising.
They highlighted that both ads were subject to targeting restrictions. The TV ad aired post-watershed, and the VOD ad appeared on a platform with parental controls, which reduced the likelihood of the ads being seen by children.
They also said the ads made only factual references to the product’s name, branding and how it worked, without using child-oriented visuals or making comparisons to games popular with children. They believed that type of content was permitted under CAP Guidance, which allowed advertisers to refer to the names, logos and functions of products, provided those references were neutral and not likely to have strong appeal to children. Overall, Ladbrokes believed the term, imagery and function of Ladbucks reflected an adult-oriented rewards scheme, and that the ads were unlikely to be of strong appeal to under-18s. They said the ads complied with the Codes and accompanying guidance on brand names, visuals, and product references.
Clearcast did not believe the term Ladbucks in ad (a) appealed strongly to children. They understood that the token was Ladbrokes’ version of free prize tokens within their rewards programme, and that they could have been used on certain promotional offers until they expired. They did not believe the tokens were similar to in-game currencies, in which those were tokens which principally had to be purchased.
Channel 4 believed ad (b), which was broadcast on their streaming service, was compliant with the Code.
Assessment
1. & 2. Not upheld
The CAP and BCAP Codes stated that gambling ads must not be likely to be of strong appeal to children or young persons, especially by reflecting or being associated with youth culture. Where appropriate steps had been taken to limit the potential for an ad to appeal strongly to under-18s, the rule did not prevent the advertising of gambling products associated with activities that were themselves of strong appeal to under-18s (for instance, certain sports or playing video games).
The ASA acknowledged that the TV ad aired post 9 pm and that both the TV and VOD ads appeared on platforms which had age-restricted controls. However, the guidance also stated that content which might otherwise be of “strong appeal” to under-18s was only acceptable in environments where, for all practical purposes, under-18s could be entirely excluded from the audience, for example in environments where those who saw the ads had been robustly age-verified as being 18 or older. We considered that a TV watershed and VOD age restrictions were unlikely to entirely exclude under-18s. As such, those measures did not remove the requirement to comply with the strong appeal rule.
The CAP and BCAP guidance “Gambling and lotteries advertising: protecting under-18s” stated, “marketers should exercise particular caution when depicting product features similar to recognisable video games, online games or social games popular among under-18s, or common features of such games in general, like loot boxes and skins”.
In addition, the guidance stated, “advertising for gambling products that have characteristics likely to be of ‘strong’ appeal to under-18s (like certain online games) may include generic depictions or references to the creative content or gameplay of the product”. Similarly, “advertising for gambling products associated with a subject of ‘strong’ appeal may include generic depictions of the subject of the gambling product”. That allowed, for example, ads for bets on football or an online game resembling video games popular with under-18s, which would otherwise be banned outright owing to the inherent ‘strong’ appeal to under-18s of those underlying activities. To help meet the requirement to limit the potential for those ads to appeal strongly to under-18s, references to ‘activities’ that were the subject of the gambling product being advertised must be limited to: text or audio references to the activity/product; generic depictions of the sport or game; logos of teams/competitions that were the subject of a product; advertisers’ brand logos/identifiers; lottery prizes and good causes; and limited use of persons or characters who passed the test set out in the guidance.
The guidance specifically stated that generic depictions must be suitable and not, of themselves, likely to appeal strongly to under-18s, “for instance, because they invite obvious comparisons with video games or online games popular with under-18s”. Therefore, we considered it was acceptable to depict the Ladbucks reward tokens and wider promotion, even if it resembled video games popular with under-18s. However, the depiction of the token and promotion in the ad must not invite obvious comparison with such games.
At the time the ads were seen, popular online games amongst under-18s – Fortnite and Roblox – used in-game currencies called V-Bucks and Robux, which were depicted as tokens and used to buy virtual items. Given the vast popularity of those games, we considered many under-18s were likely to be familiar with their in-game currencies. Because of that, their names and imagery were strongly associated with youth culture. We considered that many under-18s would have understood more generally that online games often used tokens to make gameplay purchases.
The service the ads promoted was Ladbrokes’ rewards programme, with the central characteristic of that service being the name and design of the Ladbuck token. As the central creative of the ads was a stylised token, we assessed whether characteristics of the ads, specifically the Ladbuck name and token, would be reminiscent of the tokens used in Fortnite and Roblox in a way that meant they were of strong appeal to under-18s. As part of that assessment, we assessed the likelihood of the Ladbuck being viewed only as a generic depiction of a token or whether the ads created an obvious comparison with the specific online game tokens used in Fortnite and Roblox.
We first considered that the word Ladbuck, in isolation, was unlikely to draw obvious comparisons with the online currencies V-Bucks and Robux.
We then assessed whether the depiction of the token, in combination with the name Ladbuck, created an obvious comparison with V-Bucks and Robux.
The appearance of the Ladbuck shared some generic features with in-game currencies. It was displayed in a poker-chip style that was similar to the current depiction of the V-Buck. Both coins were round and the Ladbuck had the initials ‘Lb’ in the centre. Similarly, the V-Buck had the initial ‘V’ in its centre. Both coins were also shiny around their borders. We understood that Robux had previously been shown in a coin-like form, but that design had been discontinued in 2019. The pre-2019 version of the coin, which we considered some under-18s might have been familiar with, had the initial ‘R’ in its centre, but did not have a shiny border.
Despite having some similar features, we considered that poker-chip styling primarily reflected long-established gambling conventions, which was adult-oriented. Further, bespoke coin-style tokens were also widely used to illustrate rewards and loyalty schemes in adult-facing sectors, so the use of a stylised token was not specific to children’s gaming. We also considered that there were distinct, material differences between the coins. The Ladbuck was translucent and dark red. The V-Buck was bright, futuristic in style and blue. The most recent Robux depiction was a geometric icon without internal lettering. We also considered that the depiction of the Ladbuck, although animated, was not shown being used in a manner which drew references to aspects of particular video games.
More generally, the plain red-and-white setting and plain typography of the ads were distinct from the bright, varied and highly animated environments of Fortnite and Roblox. Outside of stating they could be spent in the Ladbuck Arcade, the ads did not portray or describe specific details about how a Ladbuck was used, which meant under-18s were unlikely to draw parallels between the application of the token in comparison to V-Bucks and Robux. Although V-Bucks and Robux could be used within their games to make purchases, we considered the depiction of the Ladbrokes Arcade was generic and therefore unlikely to be reminiscent of how the coins were used in online games popular with children, and therefore not of strong appeal.
We also considered the brief appearance of slot game names, including Fishin Frenzy and Goldstrike, which were depicted alongside Ladbuck tokens. Whilst the game names appeared in bright colours that made them stand out, we considered the names were shown only momentarily and without child-like imagery or animation. The fleeting references, and the absence of related visuals, were therefore unlikely to be of strong appeal to under-18s.
We considered that although the name Ladbuck alongside the token’s imagery created some parallels with in-game currencies popular with under-18s, those similarities were not obvious enough to make the ads likely to be of strong appeal to under-18s. Those similar features were generic and did not invite an obvious comparison with the tokens used in Fortnite and Roblox. Therefore, we concluded the ads were not likely to be of strong appeal to under-18s.
We investigated ad (a) under BCAP Code rule 17.4.5 (Gambling) and ad (b) under CAP Code rules 16.1 and 16.3.12 (Gambling), but did not find them in breach.
Action
No further action necessary.
