ASA William Hill Ruling Confirms Fine Print Cannot Override Headline

The Advertising Standards Authority (ASA) has ruled that William Hill breached UK advertising rules by running a misleading in-app promotion during its Marble Race Live campaign in May 2025. The decision, published on October 29, 2025, establishes a new compliance standard requiring that promotional headlines clearly state qualifying conditions at first contact.

The ad, which appeared in William Hill’s mobile app between May 17 and 19, 2025, offered customers “£40 in bonus funds when you stake £20.” However, the small print required a minimum stake of £40, contradicting the main offer. The ad was shown to 3,057 users before being withdrawn.

The ASA ruled that this contradiction breached CAP Code 3.1 (misleading advertising) and 3.9 (qualification contradictions). While qualifications can clarify a claim, the regulator determined that in this case the fine print contradicted the headline rather than clarified it.

As a result, the ad “must not appear again in the form complained of,” the ASA stated.

The ruling marks a turning point in how operators must design and display promotional content. The ASA reaffirmed that significant conditions – such as stake thresholds, payment limits, and time restrictions—must be clearly visible where the promotion is first seen, not deferred to subsequent screens or buried in terms and conditions.

The case extends the precedent set by the 2024 Apple Pay ruling, in which payment method exclusions were deemed significant conditions requiring disclosure at first contact. Under the same principle, stake requirements must now appear in the same visual frame as the main promotional message.

The ASA referenced CAP Codes 3.1, 3.9, and 3.10, noting that “small canvases” like app banners are no excuse for omitting key qualifiers. Operators must ensure that material details are presented clearly and prominently, even where space is limited.

William Hill attributed the discrepancy to a manual error during creative resizing, claiming the qualifying stake was accidentally changed from £40 to £20 during template adaptation. The ASA, however, rejected this explanation, finding that the contradiction was material and misleading regardless of intent.

The ruling exposes a broader issue in gambling marketing workflows: version control and compliance governance. Each resizing, localization, or variant of a campaign can introduce inconsistencies, especially where numerical values – such as stakes or bonus amounts – are manually edited.

The ASA emphasized that these are not production errors but compliance failures. It urged operators to treat creative edits and translations as compliance checkpoints, requiring joint approval from marketing and legal teams before launch.

To avoid breaches under the new interpretation, the ASA advises operators to adopt the following principles:

• Present the offer and its condition together, within the same visual frame.
• Include all significant conditions—such as stake thresholds, time limits, and eligibility—at first contact.
• Assign ownership of numerical values to compliance or product teams to prevent discrepancies across variants.
• Maintain a sign-off trail confirming both Legal and Compliance approvals for each creative version.

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This is not William Hill’s first encounter with the ASA in 2025. The operator was also censured on September 24, 2025, for a same-day voucher promotion that limited redemption hours, breaching CAP 8.5 for encouraging excessive play.

Together, these decisions signal that the ASA is tightening oversight of gambling marketing, particularly in mobile and app-based environments where layout constraints have often led to deferred or incomplete disclosures.

Under the new standard, “first-contact clarity” is now a mandatory element of compliance design. As the ASA stated, deferred disclosure is no longer acceptable—fine print cannot undo a misleading headline.

Source:

, sigma.world, November 3, 2025.