UK advertising bodies to consult on children in lottery ads

29 November 2019

The UK’s Committee of Advertising Practice (CAP) and the Broadcast Committee of Advertising Practice (BCAP) have launched a new consultation over proposals to change current rules in order to allow children to play a greater role in certain lottery adverts.

Authored by BCAP, the current UK Code of Broadcast Advertising (BCAP Code) limits the amount that minors can appear in adverts related to lottery products and the good causes they support.

Rule 17.15 states that marketing communications for a lottery product should not feature anyone under 25 either gambling or playing a significant role. Rule 17.16 says adverts promoting good causes may not include children or young people in a significant role.

However, in the executive summary of the consultation, CAP and BCAP said they have become aware of a “potentially disproportionate impact of their rules on lottery advertising”. They said this may prevent some lotteries from featuring the beneficiaries of lottery funds in advertising to a point it may be too strict.

The consultation will focus on whether the current rules should be amended to address this issue, while at the same time maintaining a high level of protection for young people.

The proposals include amending the rules to allow ads for lotteries to feature their beneficiaries, alongside a call to action to purchase a lottery ticket, but exclude ads for scratchcard and online instant-win products from featuring under-25s in significant roles

CAP and BCAP also said they would retain the existing protections for children of ensuring that ads do not contain content that may appeal particularly to them.

Under the proposals, Rule 17.15 of the BCAP Code would be changed so that ads for lotteries must not feature anyone who is, or seems to be, under 25 gambling.

Rule 17.16 would also be updated to read that adverts for lotteries with reference to scratchcards or online instant-win lottery products must not feature under-25s in a significant role.

However, this would be accompanied by two clauses that clarify when children can be included in a significant role in such ads. The proposed Rule 17.16.1 states this would be permitted if they were being used to depict good causes supported by the lottery, without explicit encouragement to purchase lottery products.

In addition, Rule 17.16.2 would state that children could play a significant role in the advert if the lottery primarily benefits under-25s and the children featured are representative of the primary beneficiaries of the lottery.

The consultation will run for an eight-week period, through to January 23, 2020. CAP and BCAP said they are seeking opinion from stakeholders with an interest or expertise in lotteries and gambling risk factors. Responses can be emailed direct to CAP via AdPolicy@cap.org.uk.

After CAP and BCAP analyse the responses, an evaluation of the consultation will be published on the CAP website.

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