Background
Note: this Ruling replaces the Ruling published on 5 November 2025. Following Independent Review the wording of the Ad Description, Issue, Response and Assessment has changed to clarify the boundaries between editorial and ad content, but the decision to not uphold the complaint remains.
Ad description
An ad, for Match Bingo, seen in May 2025 on the 442oons YouTube channel, which showed comedic animation videos about football.
The ad appeared in two parts, around editorial content in the form of an animation video featuring the Tottenham Hotspur football team and other football-related figures singing a song.
The first part of the ad ran at the start, in the first five seconds of the video. An animated presenter announced, “Spurs win the Europa League, sponsored by Match Bingo – where football meets the thrill of bingo.” A phone, the word “WIN”, a football and a bingo card were shown, alongside the Match Bingo logo and text that stated, “Play along with live sports and you could WIN CASH PRIZES”. Small text stated, “18+ UK only. Bingo is a game of chance, please gamble responsibly”. The GambleAware logo and “#ad featured on screen.
The second part of the ad ran in the final 22 seconds. The animated presenter said, “Play Match Bingo during this weekend’s football and win cash prizes. Links below. Your bingo card is filled with 15 live match events, like free kicks, corners and shots off target. One line, two lines or a full house equals a win!” The GambleAware and Match Bingo logos and the small text were identical to the first part of the ad. Text stated, “Play along with live sports and WIN CASH PRIZES Watch your cards fill up in real time…”, Another bingo card was shown underneath text that stated, “The action on the pitch automatically marks off your card”. The presenter was shown rising from the sofa and running upstairs, singing “Glory, glory Match Bingo!” to the tune of the song featured in the video. The final screen featured the presenter with a bag of money alongside the Match Bingo logo and text that stated, “Real Sports. Real Bingo. Great Prizes.” He said, “Links below, 18+ Be gamble aware. Good luck!”
Issue
The complainant challenged whether the ad was appropriately targeted.
Response
Match Bingo confirmed that they had editorial control over the sections at the beginning and end of the video, which advertised their brand and for which they had made payment to the 442oons channel. The middle section of the video, which featured the Tottenham Hotspur song, was editorial content and not under Match Bingo’s control, although they had reviewed it for suitability in advance of placing the ad. Match Bingo pointed out that they had strict age verification measures in place to prevent underage consumers from accessing their products, and that it would therefore not be logical for them to seek to target those consumers.
Match Bingo had obtained demographic information from 442oons in advance of placing the ad, which showed that over 91% of their audience was 18 years of age or over. All content on the 442oons channel was marked as “Not made for kids” so that the YouTube algorithm would direct the content away from children.
Match Bingo said the video was developed with an adult audience in mind and did not use features typically associated with children’s media. The imagery, although animated, did not feature cartoon style or childlike characters. The “Glory Glory Tottenham Hotspur” song became popular among Tottenham fans in the early 1960s, the featured version having been recorded in 1981 by Chas & Dave, a musical duo whose appeal was strongly rooted in an older demographic. Match Bingo believed the humour in the video was subtle, satirical and focused largely on the politics and personalities of football management and ownership, themes they believed would not be readily accessible or engaging to children or young people.
442oons endorsed Match Bingo’s comments. They confirmed that their channel had been filtered and set up to target only adult audiences. They provided analytical data to show that the video had been marked “No, it’s not ‘Made for kids’” and that 93.5% of the video’s audience was aged 18 or over. They also sent data to show that over 90% of the audience for the channel as a whole was 18 or over.
Google said YouTube users were responsible for abiding by applicable law under the terms they agreed to. They understood that YouTube had since taken steps to prevent the content from being viewed by signed-out users or users under 18.
Assessment
Not upheld
The CAP Code stated that marketing communications for gambling must not be directed at those aged younger than 18 years through the selection of media or context in which they appeared. No medium should be used if more than 25% of its audience was under 18 years of age. In addition, age-restricted ads on social media platforms should not be targeted solely based on age data, because of younger users misreporting their age, different people sharing the same device, and non-logged-in users accessing the content. Advertisers should support that method of targeting by using interest-based factors to help remove those aged under 18 years of age from the target audience of gambling product ads.
The ASA therefore considered that marketers should be able to demonstrate that they had taken adequate steps to ensure that gambling ads were directed at an audience aged 18 and over in order to appropriately limit exposure of under-18s to such ads.
The viewing demographics supplied by 442oons showed that for the video in which the ad appeared, 6.5% of the audience were registered as being under 18. In addition, over 90% of the audience for the channel as a whole were 18 or over. Although the figures related only to users who were logged in, we noted the video had been marked as “Not Made for Kids”. We understood that “Made for Kids” labelled content that was directed at, or where the audience was mainly composed of, those under 13, and that being marked as “Not Made for Kids” made the video less likely to be recommended by the YouTube algorithm alongside other videos which were labelled as content for children. We considered this further limited the number of under-18s that would see the video.
We also considered the context in which the ad was seen and whether the ad was placed in and around content which was obviously directed at under 18s. The ad appeared on either side of editorial content, in the form of an animated song about Tottenham Hotspur football club. Because it was editorial content, the animated song fell outside of the scope of the CAP Code. We accepted that an audience could include children and young people without being obviously directed at that group and considered that the themes and the style of the animated song were not aimed at children to the extent that the ad was directed at under-18s by its inclusion around that editorial content.
Because the ad appeared in media where the under-18 audience was significantly below 25% across both the video and the YouTube channel itself, platform tools had been used to direct the ad away from children, and taking into account the themes of the wider video, which were not aimed at under-18s, we concluded that the ad had not been directed at under-18s through the selection of media or context in which it appeared.
We investigated the ad under CAP Code (Edition 12) rules 16.1 and 16.3.13 (Gambling), but did not find it in breach.
Action
No further action necessary.
