The UK Committee of Advertising Practice and the Broadcast Committee of Advertising Practice have together issued clarification on those practices that represent “normalisation,” a term that frequently features in published consultations on gambling advertising matters.
The document seeks to distinguish between the promotion of gambling as a legitimately and legally available activity, and any encouragement to gamble irresponsibly.
CAP is the self-regulatory body that creates and enforces the CAP Code, which covers marketing communications across all non-broadcast media including on marketers’ own websites. BCAP is the regulatory body responsible for maintaining the UK BCAP Code, under agreement with the communications regulator Ofcom, to regulate advertisements on television channels and radio stations.
These codes are enforced by the Advertising Standards Authority, which investigates complaints and publishes weekly rulings on complaints about specific ads each week.
The CAP/BCAP guidance states: “Largely as a result of the consultations we publish on topics such as gambling and alcohol, the CAP and BCAP will sometimes receive comments raising concerns that advertising is ‘normalising’ a particular product or associated behaviour.”
The guidance cited the gambling consultation summary of responses: “It is almost impossible to promote gambling in a ‘socially responsible’ way because ads aim to encourage people to gamble and to gamble more.”
Seeking to address the concerns, the guidance document seeks to clarify the meaning of “normalisation” in this context,
Concerns about normalisation are almost exclusively raised in relation to age-restricted products: “For some products, particularly alcohol and gambling, their careful treatment under the Codes reflects the fact that some groups may have moral or sociological concerns that go beyond concrete effects on health or wellbeing.
“CAP and BCAP acknowledge that these products attract sensitivities beyond most others, and that particular care must be taken over policy positions that relate to them.”
The concerns raised are often that advertising normalises the take-up of a particular product category. With some viewing all forms of gambling as inherently problematic, even when practiced infrequently and with restraint.
“Nonetheless, such products and services are legitimately and legally available, and have no statutory restrictions on their general promotion,” the guidance reads.
“CAP and BCAP acknowledge the place of these products as legitimate and legally-available, widely regarded as capable of being used responsibly.
“As such, the normalisation of such products and services does not present a policy concern. Preventing or reversing the normalisation of such products is therefore not a policy objective for CAP and BCAP.”
However, the committees will consider “the normalisation of irresponsible use of age restricted or other products with the potential for problematic use. This may include problem gambling,” and strict content rules apply.
The guidance references an ad for 888 in the UK that was ruled against for suggesting that gambling could be an escape from depression and a solution to financial problems.
In conclusion, “CAP and BCAP consider that the existing content rules for advertising, as well as the general principles that ads should not cause harm or be socially irresponsible, are sufficient to address concerns about the normalisation of problematic use of commonly
“However, where evidence exists to suggest that potentially irresponsible use is being promulgated through advertising, CAP and BCAP will assess it in line with our published approach to evidence-based policy making.”
The full document can be viewed on the ASA website here.