Ad description

A website for Accumulator Generator,, a betting system seen on 16 March 2017, contained text which stated "This simple system is designed to make you up to 20% profit [underlined] on your investment! - A simple, brilliant online betting system that makes you up to £10 for every £50 spent ... Every time you place a bet, you PROFIT 20% - or - £10 ... Accumulator Generator is valued at £199 + VAT ... you can unlock Accumulator Generator ... for just £1 for a 14 day trial ... ".


The complainant challenged whether the claims "... up to 20% profit on your investment" and "Every time you place a bet, you PROFIT 20%" were misleading and could be substantiated.


Accumulator Generator said their system was designed to work in conjunction with bookmakers' accumulator refund offers. They said the system worked by placing an accumulator bet on the outcome of a football match with a bookmaker who had a free bet refund offer if a team lost, and then making a similar bet against that outcome with another bookmaker, with a gap of three hours or more between the two bets. They supplied screen footage of the process of inputting odds and stakes, making calculations and checking results. Accumulator Generator said they did not claim that earnings were guaranteed and that, while the target of the system was to make 20% of your stake in profit, they used the words "up to" to convey to consumers that the amount could be less. They supplied a list of potential bets that were available at the time of their response. For each, they provided an estimated value for each accumulator offer that they considered to be the long run average profit someone could expect to make if they completed the same offer over a large enough sample of bets. The estimates were based on placing a £50 bet and receiving a £50 free bet refund if one team let them down on their accumulator.



The ASA noted that the claims appeared in the context of a ten-page document which began with the heading "ACCUMULATOR GENERATOR" followed by large text which stated "IMAGINE Placing A Bet Were [sic] You Can Lock In A PROFIT Regardless of the outcome - Whether You Win or Lose, You STILL Make Money!". More text then stated "No matter how many bets you place - No matter if this is your very first bet EVER - No matter if you've been on the losing end of bets for YEARS - With ZERO effort on your part, you come out ahead". The document continued with a mixture of headings and larger and smaller text making strongly positive statements that referred to, for example: the wish for a betting system "that allowed you to collect money regardless of the outcome"; to Accumulator Generator being a system "... that allows you to bet as many times as you want - PROFIT EVERY TIME - Collect unlimited profits"; a "win-win scenario every time, with ZERO time and effort on your part! (In fact, with a tap of your finger on a phone or computer mouse, you WILL profit from these bets!)"; and "Imagine the possibilities. Make just 5 simple bets per day and you make an additional £50 a day ... Yes! You WILL make a profit on every bet regardless of any outcome!". We considered readers would interpret the ad to mean that this was a betting system from which someone was certain to make money, even if they had relatively little experience or expertise, with a significant proportion of subscribers achieving a 20% profit.

We understood that Accumulator Generator's betting system worked as a "matched betting" system in which subscribers bet for and against particular outcomes with two different gambling operators using their "free bet" offers. Where one of the bets was a promotional "free bet," a profit could be made because the customer did not have to pay for the stake.

We considered that, theoretically and if used correctly, the betting system would eliminate the chance of losing a bet. However, the process – which included meeting the requirements for unlocking the "free" bets and manually placing the correct bets with separate gambling operators, the correct period of time apart – was long-winded and open to human error. We noted that Accumulator Generator had supplied an explanation of how the system worked but had not supplied substantiation which showed that all subscribers made a profit, with a significant proportion achieving a 20% profit. We therefore concluded that the claims had not been substantiated and that the ad was misleading.

The ad breached CAP Code (Edition 12) rules  3.1 3.1 Marketing communications must not materially mislead or be likely to do so.  (Misleading advertising) and  3.7 3.7 Before distributing or submitting a marketing communication for publication, marketers must hold documentary evidence to prove claims that consumers are likely to regard as objective and that are capable of objective substantiation. The ASA may regard claims as misleading in the absence of adequate substantiation.  (Substantiation).


The ad must not appear again in its current form. We told Accumulator Generator not to claim or imply that all subscribers would make a profit, or that any profits would be at a particular rate, unless they held adequate evidence.

CAP Code (Edition 12)

3.1     3.7    

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