CAP provides clarity on lottery advertising with U-25s

The Committee on Advertising Practice (CAP) has made two amendments to two sections of its code around lottery advertising, focusing on product promotion to under-25s.

Specific wording around certain advertising caveats has been updated, although CAP has stressed that the changes have been made to provide more clarity to companies which also do not impact advertising policy and practice.

Clarification has been made regarding the use of people in lottery adverts who are – or seem to be – under the age of 25. This falls in line with a general rule on gambling advertising, which has seen CAP and the Advertising Standards Authority (ASA) seek to curb the potential appeal of gambling products to people in this age demographic.

Of note, however, is the clarification that people who ‘seem to be’ under 25 age are banned from gambling and lottery advertising to promote products, even if the individuals in question are aged above this group.

The ASA explained that it ‘sometimes considers cases where actors who are over 25 appear to be very young for their age and might contravene the restriction’.

Changes specific to lotteries include a requirement that references to scratch cards or online instant-win lottery products must not feature above-mentioned under-25 individuals ‘in a prominent role’.

However, lotteries have been given some leeway when it comes to the promotion of good causes, with younger people allowed to feature in advertising as long as the material depicts charitable efforts and doesn’t encourage a lottery purchase.

This includes if the under-25s in question are ‘representatives of the primary beneficiaries of the lottery’, and if the lottery and its campaigns serve to specifically benefit under-25s, including in a family setting.

For example, The Health Lottery – CEO of which Lebby Eyres explained to SBC earlier this year focuses on issues such as tackling health inequality – could feature under-25s in advertising if said advertising is showcasing the impact of its healthcare funding initiatives on this age group.

The ASA explained that after conducting its review into the wording of lottery advertising rules, CAP determined that ‘it would be unreasonable for the Codes to prohibit a lottery provider from depicting beneficiaries like a children’s hospice, or young people’s sport and activity scheme’.

This policy has been in place since 2020, but CAP felt that greater clarity was needed to ensure lottery operators are aware of what can and can’t be done regarding advertising.

The updates do come at a time of heightened scrutiny on gambling from the ASA. However, with the authority having recently upheld two separate challenges against Ladbrokes for material posted on Twitter which was deemed to have an appeal to under-25s.