UK gambling operators are facing increased regulatory scrutiny after the Committee of Advertising Practice (CAP) and the Advertising Standards Authority (ASA) announced a new compliance initiative.

The initiative targets social media content that could appeal to under-18s, but, despite it looking like more scrutiny for operators, some may see it as progression.

An enforcement notice has been issued to all gambling businesses, warning that, from 11 June, it will begin actively monitoring content using the ASA’s AI-powered Active Ad Monitoring System.

Gambling authorities and social media to work together

A key milestone here is that the monitoring will be supported by partnerships with major social media platforms. 

Operators found to be breaching advertising rules will be required to remove or amend content immediately, with persistent non-compliance potentially resulting in referrals to both platform operators and the Gambling Commission.

While gambling operators may be stung through their direct social media advertising, sanctions may also be imposed on affiliate-style marketing. 

“If we identify ads that break the rules, we will require you to amend or remove the ad immediately and, if you fail to comply, we will impose sanctions, which may include referral to the platform hosting the ad and/or the Gambling Commission,” the notice read.

The regulated industry in the UK has come under all manner of pressures in recent times, not least through heavier regulation and tax burdens, and this new clampdown on social media advertising may feel like yet another kick in the teeth to operators on these shores.

However, stepping back and taking a wider look at the situation, partnerships with social media platforms and heavier scrutiny on social media marketing may be a step in the right direction of tackling black market advertising on social media. 

Eliminating, or at the very least reducing, the scale of the UK’s black market has been a long-time proposal of the regulated market, yet the size of it continues to grow.

The outlandish social media marketing tactics by these platforms have been highlighted online, and whilst it is easy to say they need to be stopped, tackling them is a whole different ball game.

But, to be fair to the Gambling Commission, it has acknowledged that something needs to be done to stop this. At ICE Barcelona in January, Tim Miller, Executive Director of Research and Policy, took aim at Facebook and Instagram owner Meta’s inaction.

“If we can find them, [businesses promoting themselves as “non-GamStop casinos”] then so can Meta: they simply choose not to look,” he declared.

“It could leave you with the impression that they are quite happy to turn a blind eye and continue taking money from criminals and scammers until someone shouts about it. So it 

does leave Meta with the question of ‘Whose side are you on?’”

What is the ASA’s Active Ad Monitoring system?

There has been a lot of talk around the ASA, particularly following on from its decisions on various gambling adverts last week, so let’s break down what its Active Ad Monitoring system actually is. 

The ASA’s Active Ad Monitoring system is an AI-powered regulatory tool designed to help monitor the vast volume of online advertising more efficiently and proactively. 

It continuously captures and analyses large numbers of online ads, helping the ASA identify potential breaches of advertising rules at scale.

The system combines three core components:

• Ad capture at scale – the system captures ads from social media, search and display using a mix of public sources, our own internal monitoring tools and proprietary datasets 
• AI-based filtering – machine learning models are configured to spot the ads that are most likely to be relevant to a given issue, or to have specific compliance problems 
• Expert review – our experts can browse and search content related to their work via a web interface that allows them to quickly assess issues, and identify problematic examples for  action

One step closer to lines being drawn by the ASA?

The initiative as a whole focuses on CAP Code rule 16.3.12, which prohibits gambling adverts from being likely to have a strong appeal to children and young people – though the lines on this are blurred.

Content linked to the 2026 World Cup could face particular scrutiny if it incorporates team imagery or fan content that appeals to younger audiences.

Regulators say recent investigations continue to uncover gambling marketing that uses imagery, personalities and branding likely to resonate with under-18s despite previous guidance and enforcement action, and highlighted several recent rulings, some of which have come under fire.

These include advertisements featuring current Premier League footballers, England internationals and globally recognised stars such as Erling Haaland, Harry Kane, Trent Alexander-Arnold, Son Heung-min and Lewis Hamilton. 

Guidelines being somewhat drawn, or at least further reasoning being given for rulings, is another small step forward. One of the rulings last week OKayed a Betway advert featuring Thierry Henry, due to the Arsenal legend being not of a significant appeal to a younger generation, having been retired since 2014.

However, late last year, the regulator ruled against a Sky Bet advert featuring Gary Neville – an ex-player who has been retired since 2011 and holds relatively similar industry roles to Henry now. 

This sparked debate on there being no clear do’s and don’t’s for operators, but has been clarified to some extent now.

The guidance makes clear that retired athletes and media personalities are not automatically exempt. The ASA considers factors such as social media followings, audience demographics, commercial partnerships and wider cultural relevance when assessing whether an individual has strong appeal to minors. 

Neville’s ad breached the rules, while the Henry advert and another Fitzdares promo featuring former England cricketer Stuart Broad were deemed compliant due to lower youth appeal – but what’s the difference?

Broad, as well as Henry, had “low absolute numbers of under-18 followers” on social media, whereas Neville’s “wider work and social media profile indicated he had a significant number of under-18 followers”. 

It is important to note that the numerical limit to these under-18 followers in order to not trigger an ASA warning is unclear.

The ASA also reiterated that operators should not assume social media audiences are exclusively adult simply because platforms use age declarations. 

Referencing Ofcom research and previous ASA decisions, the regulator noted that significant numbers of underage users register accounts with false dates of birth, meaning gambling content can still reach children even where audience data suggests otherwise.

Operators are being advised to review CAP’s updated guidance on protecting under-18s, as well as recent ASA rulings, before the new monitoring programme comes into force.

With the World Cup and a packed summer sporting calendar expected to generate significant marketing activity across the sector, the new AI-led monitoring initiative signals more stringent regulations for the licensed market.

However, the positive for these operators is that it may be the first in a long line of steps towards tackling black market advertising, which is targeting both UK adults and children.