The ASA has reprimanded a promoted tweet for Ladbrokes, seen in October 2022, featured the text “Can these big summer signings make the question marks over their performances go away?”.

The tweet contained an embedded video showing an image reel of Premier League footballers Philippe Coutinho, Jesse Lingard and Kalidou Koulibaly, set against a background of question marks, with the text “Ladbrokes” within the image box itself.

The ASA challenged whether the ad included individuals who were likely to have strong appeal to those under-18 years of age, and therefore breached the code.

Ladbrokes said their marketing team had carefully incorporated CAP’s guidance on gambling ads having strong appeal to under-18s in their practices. They acknowledged that football and top-flight footballers were considered to carry a high risk of having strong appeal to children, and they had therefore made use of all available targeting and age-gating tools to remove under-18s from the ad’s audience. 

The ASA considered that it would have been acceptable for the ad to appear in a medium where under-18s, for all intents and purposes, could be entirely excluded from the audience.

That would apply in circumstances where those who saw the ad had been robustly age-verified as being 18 or older, such as through marketing lists that had been validated by payment data or credit checking. We did not consider that marketing data inferred from user behaviour met that threshold. Because Twitter was a media environment where users self-verified on customer sign-up, and did not use robust age-verification, we considered that Ladbrokes had not excluded under-18s from the audience with the highest level of accuracy required for ads the content of which was likely to appeal strongly to under-18s.

For those reasons, we considered that the ad was irresponsible and breached the code.