Background
This Ruling forms part of a wider piece of work on gambling ads, identified for investigation following complaints received and intelligence gathered by the ASA. See also related rulings published on 27 May.
Ad description
A paid-for Facebook ad for Mr Vegas, seen on 5 February 2026, included an image with the headline “MR VEGAS CASINO SLOTS SPORTS” on a black brick wall and featured five tiles with imagery relating to five online, gambling games. Text in the caption stated “New games every. single. week [sic] [loveheart face emoji]”. Further text that set out the terms for playing the games stated, “Play Responsibly” and linked to Gamble Aware.
One tile included the text "PiNK ELEPHANTS 2" [sic] with a large pink cartoon elephant, backlit by beams of light on a lilac background.
Another tile featured a large robotic, cartoon shark with its jaws around the text "RAZOR RETURNS", on a cartoon background showing an ocean, landscape and sky.
A third tile was candy themed and featured bright, multi-coloured, bubbly text that stated, "SWEET BONANZA", on a blue and pink background.
A fourth tile showed an animated fisherman, backlit by beams of light and holding a large fish, and the text “BIG BASS BONANZA”.
The ad included “18+", "BeGambleAware.org" and "GAMSTOP" logos.
Issue
The ASA challenged whether the ad featured content likely to be of strong appeal to under-18s and therefore breached the Code.
Response
Videoslots Ltd t/a Mr Vegas said that the four game tiles featured game imagery: that is, artwork that was intrinsic to, and inseparable from, the branded identity of the games. Those games were commercially published slot games by established game developers, licensed by the Gambling Commission and intended exclusively for adult audiences in regulated gambling markets. Mr Vegas understood that cartoon-style graphics were not automatically prohibited in gambling advertising, it depended on whether the execution and context were adult in nature. They believed the tiles in their ad fell into that category.
Mr Vegas said that Sweet Bonanza’s candy-themed aesthetic and bright colours were an artistic choice by the game developer to evoke fun and excitement for adult players. The imagery did not depict children's characters, licensed children's media or content specifically targeted at under-18s. They said that no character, such as a person, mascot, or figure of any kind, was depicted in the tile. Instead, it featured only the stylised game logo and background artwork. They said that candy-themed imagery was widely used for adult audiences. They believed that it did not, of itself, have strong appeal to under-18s. They took the view that neither the word “sweet” nor the colours on their own, held strong appeal to under-18s.
Mr Vegas said that the tile for Big Bass Bonanza featured a cartoon-style fisherman who was clearly an adult male, with a full beard, which they considered was in line with the CAP Guidance, Gambling and lotteries advertising: protecting under-18s (the Guidance), that stated, “characters that are more obviously life-like and/or adult in terms of the creative style and general appearance are more likely to be acceptable”. The fisherman was not a recognisable or licensed children's character, and they believed fishing to be an activity with broad adult appeal.
They said that the tile for Pink Elephants 2 featured a stylised pink elephant on a lilac background, depicted in a psychedelic, surreal style. They believed that the eyes were presented in an intimidating or scary manner, and that the elephant’s body was surrounded by an armour-like feature. They described the imagery as abstract and fantastical. It was not drawn from children's media; nor did it resemble a licensed children’s character. They also said that it was not a soft toy, with exaggerated “cute” features, of the kind associated with children's programming.
Mr Vegas said that the Razor Returns tile featured a robotic, mechanical shark in a fantasy-ocean setting. They described the imagery as action-oriented and designed for adult players and the shark as a metallic, aggressive predator, rather than a soft, "cute", or child-friendly character. Mr Vegas said the tile had none of the hallmarks of children's programming. The setting was a dramatic fantasy seascape, which they saw as a visual convention common in adult gaming across video games and casino products. They believed that neither the game name, nor the words that formed it, were of strong appeal to under-18s.
Mr Vegas also said that robust and verifiable controls were in place to prevent the ad from being served to under-18s. The ad was configured within Meta Ads Manager with a minimum age restriction of 18 years, utilising Meta's audience targeting controls. This setting prevented the ad from being delivered to any Facebook user whose account age was under 18. They applied this age restriction across all paid social-media advertising for their gambling products and said they held documentary evidence of the targeting settings applied to the ad, including screenshots from Meta Ads Manager confirming the age restriction in place at the time the ad was live, and records of Age Reports and Placement Reports for the duration the ad was live.
Mr Vegas said they also applied audience exclusions and placement restrictions to their paid-for, social-media advertising. They said that custom audiences, who would already know the brand, and lookalike audiences, who would be new users similar to existing customers, were constructed from verified adult customer data only. No audience segments likely to feature a large number of under-18s were used. The ad was placed only on platforms and placements where Meta enforced age-verification or age-gating, consistent with Meta's policies for gambling advertisers operating under a UK Gambling Commission licence. They believed that that targeting combined with prominent, responsible-gambling messaging and logos to signal that the ad was directed at adults.
Assessment
Upheld
The Code 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. The CAP Guidance stated that high-risk types of content to be avoided included child-oriented cartoon content or animated styles. It also stated that it was prohibited for an ad to have “strong” appeal to under-18s, irrespective of its appeal to adults.
The ASA understood that the four tiles featured imagery from slot games developed by established game developers, licensed by the Gambling Commission, and intended for adult players. We considered that, even if they reflected the style and content of those games, the imagery in the tiles needed to be carefully selected to avoid being of strong appeal to under-18s.
The Guidance stated that some types of animation could be of high risk of strong appeal to children and should be avoided, including child-oriented cartoon content or animated styles and characters like “cuddly” or “cute” animals, princesses or pirates with exaggerated features.
The large, pink, cartoon elephant in the Pink Elephants 2 tile was reminiscent of children’s cartoons and story books, due to the animal imagery, style and colour palette. We considered the image was “cute” and surreal rather than scary. We also observed a similarity between the tile, and imagery and font associated with the Ice Age franchise, popular with children, which we considered increased the risk of strong appeal to under-18s. We therefore considered that the Pink Elephants 2 tile depicted in the ad was likely to be of strong appeal to under-18s.
The Guidance also stated that generic characters related to stories or themes that were popular among children, including robots, should be avoided. The Razor Returns tile featured a metallic, cartoon robot shark about to bite into the text “RAZOR RETURNS” in a bold silver and red font. The robot shark’s large and sharp teeth were therefore prominently featured. Although the Guidance indicated that characters which were more obviously adult in terms of the creative style and general appearance were more likely to be acceptable, and we accepted the image was unlikely to be considered “cute”, we considered that the image was recognisably a robotic shark with exaggerated features, set against a brightly coloured seascape and landscape background, and considered the image was likely to appeal strongly to under-18s.
We understood that the tile for Sweet Bonanza had a candy theme, but considered that any imagery which might have been identified as a sweet or sweet wrapper was obscured. We considered the bright, multi-coloured, bubbly text on a blue and pink background, displayed no prominent or specific features or characters that would appeal strongly to under-18s.
We considered that a fisherman was the type of character that could be found in a children’s animated programme, but acknowledged that the fisherman in the Big Bass Bonanza 2 tile was not a recognisable or licensed children's character. He was dressed in muted green and khaki colours, and the fish he was carrying, whilst recognisably animated, appeared more life-like than exaggerated or fantastical. The Guidance indicated that characters that were more obviously life-like were more likely to be acceptable. We also considered that fishing was an activity less likely to appeal strongly to under-18s.
We considered that it would have been acceptable for gambling ads which featured content likely to be of strong appeal to children to appear in a medium where those aged under 18, for all intents and purposes, could have been entirely excluded from the audience. That would apply in circumstances where those who saw the ads had been robustly age-verified as being 18 or older.
Ofcom’s report from May 2025, ‘Children and parents: media use and attitudes’, discussed media use, attitudes and understanding among children in the UK. It stated that 30% of respondents (namely their parents) said that their child used Facebook, but that figure represented the proportion of usage amongst all 3- to 17-year-olds. The figure rose to 56% of 16- to 17-year olds. Given that evidence, we considered that a large proportion of under-18s used Facebook.
We understood that Meta had introduced Teen accounts to Facebook, with more restricted settings, before the date on which the ad was seen. However, Facebook Teen accounts relied on users’ self-declared age. We understood that age self-declaration was only part of Meta’s age assurance approach and that it was supplemented with methods such as users’ video selfies or uploading identity documents. However, Ofcom research based on a 2025 survey (sample of 1,793 social media users aged 8–17 years) estimated that 20% of 8- to 17-year-olds with their own profile on an online service had a registered user age of at least 18 years. Given that evidence, we considered that it was likely that there was at least a significant number of children who had not used their real date of birth when signing up to Facebook, who were able to see and access content intended for those aged 18 or older. That would include Mr Vegas’s paid-for advertising, despite the controls, exclusions and restrictions we understood they had implemented.
For those reasons, we concluded that the ad was irresponsible and breached the Code.
The ad breached CAP Code (Edition 12) rule 16.3.12 (Gambling).
Action
The ad must not appear again in its current form. We told Videoslots Ltd t/a Mr Vegas not to feature content likely to be of strong appeal to those under 18 years of age.
