Background
This ruling forms part of a wider piece of work on gambling ads. The ad was identified for investigation following intelligence gathered by our Active Ad Monitoring system, which uses AI to proactively search for online ads that might break the rules.
Ad description
A paid-for online display ad for Casumo, an online gambling website, seen in August 2026, featured text that stated “UP TO 100 SPINS ON SPINUMO” alongside a “Sign up” button and the text “QUEST. SPIN. WIN.” The ad also included the Casumo logo and an image of a person in festive clothing.
Small print stated “18+ UK players only. Opt-in required. From 6 July 2026 – 2 August 2026. Complete daily mission (Deposit £50 and Wager £200) to earn 1 Spinumo wheel spin, up to 5 Spinumo wheel spins per day. Win free spins (£0.10/spin) up to 100 spins. Free spins expire in 48 hours. Full T&Cs apply. BeGambleAware.org”.
Issue
The ASA challenged whether the ad breached the Code because it encouraged behaviour that was socially irresponsible or could lead to financial harm.
Response
Recro Ltd t/a Casumo said the promotion was a targeted, opt-in offer available to eligible UK customers. Customers who opted in were presented with a daily mission. To complete a mission, they had to deposit a minimum of £50 and wager a minimum of £200 on eligible games, which generated one spin on the “Spinumo Wheel”. They said customers could earn up to five spins per day, that the wheel awarded a randomised number of free spins up to a maximum of 100, and that each free spin was worth £0.10. They said the free spins expired 48 hours after being credited and that no wagering requirement applied to winnings from those free spins.
They said that although completing five missions in one day could amount to deposits of up to £250 and wagering of up to £1,000, those figures were the maximum possible qualifying activity and not a requirement for all participants. They said customers who wanted one wheel spin needed to complete only one mission, that customers could decide after each mission whether to complete another, and that wagering was not the same as loss. They therefore did not believe the promotion encouraged frequent or repetitive gambling or created pressure to gamble again on the same day.
They said the wording “QUEST. SPIN. WIN.” described the promotional journey and was not intended to suggest that gambling was a route to financial gain or to encourage customers to gamble more frequently, beyond their means or until they achieved a particular outcome. They also said the ad made clear the significant terms of the promotion, including the deposit and wagering requirements, the maximum daily spins and the 48-hour expiry period, and that the claim “up to 100 free spins” accurately described a genuine available reward.
Assessment
Upheld
The CAP Code stated that marketing communications for gambling must not portray, condone or encourage gambling behaviour that was socially irresponsible or could lead to financial, social or emotional harm. CAP’s Advertising Guidance on “Gambling advertising: responsibility and problem gambling” stated that marketers should take care not to encourage frequent or repetitive participation.
The ad was for Casumo’s “Spinumo” promotion, under which consumers who completed one daily mission by depositing £50 and wagering £200 received one Spinumo wheel spin. Consumers could complete up to five missions per day throughout the 28-day promotional period to obtain further wheel spins. Each wheel spin awarded a random number of free spins, up to a maximum of 100, each worth £0.10. Those free spins expired after 48 hours.
The ASA acknowledged that the promotion was targeted and opt-in, and that consumers were not required to complete multiple missions or participate every day. However, each additional mission required a further deposit £50 deposit and £200 of wagering, in return for another opportunity to receive a promotional reward. We considered that the promotion therefore directly incentivised consumers to repeat the qualifying gambling activity up to five times each day. We also considered that the potential for winning 100 free spins from each wheel spin provided a further incentive to complete additional missions, because each offered another opportunity to obtain that reward.
Completing five missions would involve deposits of £250 and wagering of £1,000 in a single day. Because the promotion ran for 28 days, maximum participation throughout that period would involve deposits of £7,000 and wagering of £28,000. While wagering was not equivalent to loss, and consumers could choose how many missions to complete, we considered that the promotion nevertheless encouraged substantial gambling activity at a regular and fixed frequency, within a limited period. The opportunity to obtain further rewards through repeated participation on the same day and on successive days, reinforced that incentive.
We also considered that the presentation of the promotion reinforced that incentive and encouraged repeat participation. The description of the qualifying activity as a “daily mission” alongside the wording “QUEST. SPIN. WIN.”, presented gambling as a challenge that could be completed repeatedly. In the context of a promotion offering up to five wheel spins per day, we considered that encouraged consumers to maximise their participation.
Although consumers could choose whether to complete further missions, we considered that the mechanic risked encouraging continued gambling, particularly among more vulnerable consumers. The optional nature of the promotion therefore did not negate our concerns about the encouragement of frequent and repetitive gambling.
We also considered the scale of the qualifying activity in relation to the potential reward. Consumers were required to deposit £50 and wager £200 for each opportunity to win up to 100 free spins worth £0.10 each, with a maximum combined spin value of £10. We considered that those requirements represented substantial gambling activity relative to the value of the potential reward and that the opportunity to repeat them increased the risk of consumers gambling more than they otherwise would.
For those reasons, we concluded the ad encouraged behaviour that was socially irresponsible or could lead to financial harm.
The ad breached CAP Code (Edition 12) rules 16.3 and 16.3.1 (Gambling).
Action
The ad must not appear again in the form complained of. We told Recro t/a Casumo to ensure that future gambling promotions did not encourage behaviour that was socially irresponsible or could lead to financial harm.
