The ASA has reversed its earlier decision on Ladbrokes’ “Ladbucks” reward tokens. The TV and VOD ads are no longer found to be in breach of the Code.

The key message for operators: generic parallels between reward tokens and in-game currencies will not, without more, render an ad of ‘strong appeal’ to under-18s, provided the depiction does not invite an obvious comparison with specific video games popular with children.

What were the ads?

The ads were a TV spot seen on 17 December 2024 and an identical VOD ad on Channel 4 on Demand on 23 December 2024. Both promoted Ladbrokes’ “Ladbucks” rewards programme, with a voice-over explaining that consumers could collect “Ladbucks” on free-to-play games and choose rewards such as free spins, free bets, and access to a “Ladbucks Arcade”.

The ads featured imagery of translucent, dark red coins displaying the initials “Lb”, alongside on-screen text referencing “100m LADBUCKS”, “FREE BETS” and “FREE SPINS”.

Two complainants challenged whether the term “Ladbucks” was likely to be of strong appeal to those under 18. In its original ruling of 11 June 2025, the ASA upheld the complaints. Ladbrokes sought an independent review, and the republished ruling reverses the original outcome in its entirety.

The rules on strong appeal

The BCAP Code (rule 17.4.5) and CAP Code (rules 16.1 and 16.3.12) provide that gambling ads must not be likely to be of strong appeal to children or young persons, especially by reflecting or being associated with youth culture. The accompanying guidance states that marketers should exercise particular caution when depicting product features similar to recognisable video games popular among under-18s. Critically, the guidance also permits generic depictions of gambling products, provided those depictions do not invite obvious comparisons with video games or online games popular with under-18s.

Why did Ladbrokes win on review?

The ASA acknowledged that in-game currencies like V-bucks (Fortnite) and Robux (Roblox) are strongly associated with youth culture. But the critical question was whether the Ladbucks name and token design invited an obvious comparison with those currencies, or whether the similarities were merely generic.

On the naming point, the ASA found that “Ladbuck” in isolation was unlikely to draw obvious comparisons with V-bucks and Robux; ‘bucks’ being accepted by the ASA as generally referring to money without necessarily being targeted at children. The question then became whether the token’s visual design, combined with the name, created an obvious comparison.

The ASA acknowledged some generic similarities: both Ladbucks and V-bucks are round, poker-chip style tokens with central lettering. But it found that poker-chip styling primarily reflects long-established, adult-oriented gambling conventions. Bespoke coin-style tokens are widely used across adult-facing sectors, so this was not specific to children’s gaming.

Crucially, the ASA identified material differences. The Ladbuck is translucent and dark red; the V-buck is bright, futuristic and blue; the Robux is a geometric icon without internal lettering. The Ladbuck, although animated, was not shown being used in a way that referenced, or invited a link with, any particular video game.

The ASA also noted that the ads’ plain red-and-white setting and typography were distinct from the bright, animated environments of Fortnite and Roblox. The ads did not show how Ladbucks were used, making it unlikely that under-18s would draw parallels. The brief appearance of slot game names was momentary and lacked child-like imagery.

What this means for the ‘strong appeal’ test

This ruling clarifies the distinction between generic and obvious comparisons under the ‘strong appeal’ test. The original ruling drew broad parallels between Ladbucks and in-game currencies based on naming, design and function. The revised ruling takes a more granular approach.

The ASA acknowledged that some generic similarities existed, but found these reflected longstanding adult-oriented gambling conventions rather than features specific to children’s gaming. The question is not whether any parallels exist, but whether those parallels are so obvious as to make the ad likely to be of strong appeal to under-18s.

The ruling also clarifies the guidance on generic depictions. Advertisers can depict the names, logos and functions of their gambling products, even where those products share some characteristics with activities popular among under-18s, provided the depiction does not invite obvious comparisons with specific video games.

Key takeaways for operators

Four practical points for operators:

• Generic similarities won’t automatically breach the Code. Operators whose reward tokens share only generic features with in-game currencies can take comfort, provided the overall depiction remains distinct.
• Visual distinctiveness matters. The ASA placed significant weight on material differences in colour, style and animation. Avoid bright, futuristic or cartoon-like styling that might invite direct comparisons with children’s games.
• Overall tone and setting count. The plain setting and typography of the Ladbrokes ads were distinct from gaming aesthetics. Consider whether your ad’s creative treatment reinforces adult-oriented associations.
• Back up your response with evidence. Ladbrokes’ detailed submission, including token design comparisons, colour schemes and examples of coin-style tokens across adult industries, appears to have been decisive. When facing complaints under the strong appeal test, granular, evidence-based analysis is essential.
• Targeting restrictions remain important but are not sufficient on their own. The ASA confirmed that TV watershed and VOD age restrictions were unlikely to entirely exclude under-18s, and therefore did not remove the requirement to comply with the strong appeal rule.
• The independent review process can produce different outcomes. Ladbroke’s successful challenge demonstrates that the ASA’s independent review mechanism is a meaningful avenue of redress.