Age Rules for Free-to-Play Casino Games and Gambling Ads

What the Commission Published in 2017 and 2018

The Gambling Commission publishes, and still publishes, its own open letter of 9 October 2017 to the editor of The Sunday Times. The Commission describes it as "An open letter to the Editor of the Sunday Times following their story on 8 October about the risks of children being exposed to gambling online." It states that "Protecting children from being harmed or exploited by gambling is a clear priority for the Gambling Commission." and that "Our rules require strong age verification checks to prevent underage gambling." It also set out what was then under way: "Earlier this year we announced that we had commenced a wide ranging review of online gambling."

On 26 June 2018 the Commission published the next step: "The Gambling Commission has set out further commitments to protecting children and young people from the dangers of gambling, building on work already underway in this area." Its executive director Tim Miller said on that page: "For example, this year we will be carrying out targeted compliance and enforcement activity to identify and tackle any weaknesses in the age verification processes."

Free-Play Games Sit Behind Age Verification

Social responsibility code provision 3.2.11 of the Gambling Commission's Licence Conditions and Codes of Practice applies to remote licences and requires that "Licensees must have and put into effect policies and procedures designed to prevent underage gambling and monitor the effectiveness of these." Among the procedures it mandates is "Verifying the age of a customer before the customer is able to: deposit any funds into their account; access any free-to-play versions of gambling games that the licensee may make available; or gamble with the licensee using either their own money or any free bet or bonus." A demo slot on a licensed operator's site is therefore behind age verification as a licence condition, not as a courtesy. The same provision requires licensees to be "warning potential customers that underage gambling is an offence;" and "enabling their gambling websites to permit filtering software to be used by adults (such as parents or within schools) in order to restrict access to relevant pages of those sites."

Breach is not a technicality. The code carries the standing note that "Compliance with these is a condition of licences; therefore any breach of them by an operator may lead the Commission to review the operator's licence with a view to suspension, revocation or the imposition of a financial penalty and would also expose the operator to the risk of prosecution."

The Rule on Advertising of Appeal to Under-18s

Advertising is governed by the CAP Code, and compliance with it is a licence condition. Social responsibility code provision 5.1.6 states that "All marketing of gambling products and services must be undertaken in a socially responsible manner." The Commission's own guidance tells licensees which parts to read, naming section 16 of the UK Code of Non-broadcast Advertising and Direct and Promotional Marketing.

The operative rule is CAP Code 16.3.12. Marketing communications must not "be likely to be of strong appeal to children or young persons, especially by reflecting or being associated with youth culture." The same rule adds: "They must not include a person or character whose example is likely to be followed by those aged under 18 years or who has a strong appeal to those aged under 18." The Code defines the terms it uses, saying that for the purposes of that section "children" are people of 15 and under and "young persons" are people aged 16 or 17, and it states its own purpose: "The rules in this section are designed to ensure that marketing communications for gambling are socially responsible, with particular regard to the need to protect children, young persons and other vulnerable persons from being harmed or exploited."

Affiliates are inside the rule, not outside it: the Code's scope section states that "This includes marketing by third parties (for example, affiliate marketers) acting on an advertiser's behalf." Separately, the Commission's marketing guidance sets an age floor on who may appear in a gambling ad at all: "As a general rule, marketing communications for gambling must not include a child or a young person. No one who is, or seems to be, under 25 years old may be featured gambling or playing a significant role."

How the Advertising Guidance Has Changed Since 2022

The current test is strong appeal, and the Commission's own page summarises the rule that way: "The CAP Code requires that marketing communications for gambling must not be likely to be of strong appeal to children or young persons, especially by reflecting or being associated with youth culture, particularly if they are generally available to view by them ('freely accessible')." It dates the supporting guidance, CAP's "Gambling and lotteries advertising: protecting under-18s", which the Commission says "was released in April 2022."

That guidance has itself been replaced. The ASA's resource page, dated 14 Oct 2025, states that "This updated CAP and BCAP guidance on protecting under-18s in gambling and lotteries advertising replaces the 2022 version." and that "The updates include new text on the role of social media in determining “strong appeal”, clarification around “adult-centric” and “non-adult-centric” sports, and a new “Context” section explaining how appeal can vary depending on setting and execution."

Enforcement has moved with it. On 4 June 2026 the Commission announced a monitoring exercise: "Today the Committee of Advertising Practice (CAP) published an enforcement notice" to all gambling businesses, and "Launching on 11 June the sweep will employ an AI-based Active Ad Monitoring System", with partnerships with social media platforms alongside it. The notice CAP issued warns operators: "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."

Fines have followed in this area too. On 21 September 2022 the Commission announced that "Online gambling business Betway Limited will pay a £408,915 penalty for marketing on the children's pages of West Ham United Football Club's website." and that "Both advertisements breached Commission rules stating gambling advertising must be socially responsible."

The Commission's Own Figures on Children and Gambling

The Commission's earlier figures are the baseline, and its announcement of them is still published. Dated 30 November 2016, it reads: "Parents and guardians are being warned to be vigilant following publication of a new report indicating that 450,000 children are gambling in England and Wales every week." and "The Gambling Commission's Young People and Gambling Report also shows that around 9,000 of these are likely to be problem gamblers." It put the overall rate at "The findings indicate that the overall rate of gambling among 11-15 year olds is around 16%."

That figure is nine years old and has been superseded. The Commission's current release, Young People and Gambling 2025, was "Published on 13 November 2025" and covers a wider age range on a different basis: "The study collected data from 3,666 pupils aged 11 to 17 years old across curriculum years 7 to 12 (S1 to S6 in Scotland) attending academies, maintained and independent schools in England, Scotland, and Wales using the Ipsos Young People Omnibus." Its headline findings are that "Three in ten (30 percent) 11 to 17 year olds had spent their own money on any gambling activity in the 12 months prior to completing the survey, with boys (34 percent) more likely than girls (27 percent)." and that "The proportion of young people who scored 4 or more on the youth-adapted problem gambling screen (DSM-IV-MR-J) and therefore representing a young person experiencing problem gambling was 1.2 percent."

The two numbers are not comparable. The 2016 figure counted weekly gambling by 11 to 15 year olds in England and Wales; the 2025 figure counts any spending of their own money over twelve months by 11 to 17 year olds across England, Scotland and Wales. The Commission's 2025 release also notes where the growth sits: the rise from 27 percent in 2024 "appears largely driven by a rise in unregulated gambling (18 percent in 2025, compared with 15 percent in 2024)."