CAP and BCAP’s revised guidance on responsibility and problem gambling


Changes to CAP and BCAP’s responsibility and problem gambling guidance announced in August came into effect on 1 November.

The CAP offers guidance on the interpretation of the UK Code of Non-broadcast Advertising and Direct & Promotional Marketing (the "CAP Code"), in relation to non-broadcast marketing communications. The BCAP offers guidance on the interpretation of the UK Code of Broadcast Advertising (the "BCAP Code"), in relation to broadcast advertisements.

The updated guidance was developed as part of the consultation process responding to the findings of the GambleAware research published in 2020. It adds to already extensive protections in the Codes to ensure that gambling advertising does not encourage or condone risky or irresponsible behaviour.

The new guidance complements existing protections in the CAP and BCAP Codes to ensure that gambling advertising is not socially irresponsible and does not lead to financial, social or emotional harm. The guidance does not create new rules but aids the interpretation of section 16 of the CAP Code and section 17 of the BCAP code. The guidance also reminds marketers to apply the rules in spirit, as well as letter.

New guidance, drawing on insights from the GambleAware research, advises marketers to:

  • 1. Avoid Presenting complex bets or other gambling products in a way that emphasises the skill, knowledge or intelligence involved and could therefore lead to erroneous perceptions of risk or control.
  • Offers for gambling products that include multiple elements (for example, urging consumers to make multiple selections or take several steps to participate in an offer) should not be promoted with undue emphasis on an individual’s skill, knowledge or intelligence. For instance, by placing undue emphasis on how these attributes might lead someone to make a particular selection or choose a more complex product over a straight-forward one. Depictions of someone using such products or generally participating are unlikely to be problematic.


  • 2. Avoid presenting gambling as a way of participating in a community based on skill. 
  • This focuses on messaging that suggests participating can make someone part of a wider community based on this attribute. It does not restrict the use of other general messaging relating to communities (social motives for gambling are acknowledged to be associated with lower risk than, for instance, gambling for financial gain) or to the benefits of joining a particular operator’s service like features that allow people to socialise with other players, either in person or virtually.


  • 3. Avoid stating or implying that offers (such as money back, free bets, enhanced odds and similar) can reduce risk.
  • This focuses on messaging playing down losing a bet or the level of risk involved; for instance, stating or implying that a bet or offer is low risk, that the outcome and/or decision to bet does not matter, that individuals can make higher risk selections or that individuals are secure because of a feature of an offer, like money being refunded for a losing bet. This builds on existing guidance in the same section cautioning against the implication that an activity or offer is without risk. It is not intended to prohibit particular offer mechanics; the focus is on how they are presented in ads.


There are also specific requirements that apply to specific sectors, in areas from food and medicines to tobacco and alcohol. For example, you can claim your drink is 'low in alcohol' only if it contains between 0.5 per cent and 1.2 per cent alcohol by volume.


The changes to the guidance also add to the guidance on Immediacy and Urgency (see section 4.3), Trivialisation (see section 4.4) and Financial concerns (section 6.2).


If you need any bespoke advice or further information contact Arianne King at