William Hill has been reprimanded by the Advertising Standards Authority (ASA) over a promotional voucher that was deemed to possibly encourage irresponsible play.
The ASA’s report stated that a customer received a voucher from a slot machine in a William Hill betting shop on 3 April 2025 at 11:51am. The voucher had the following text:
“You’ve won a £5 cash match on any game!”
“Redeemable between 03/04/2025 – 03/04/2025 from 05:20 PM – 11:59 PM in any venue”.
Within a complaint to the ASA, it was challenged whether the timeframe between the voucher being received and when it could be redeemed was a breach of the CAP code since it was “socially undesirable by encouraging irresponsible use”.
Despite William Hill arguing that the voucher didn’t breach the code or encourage socially undesirable or irresponsible behaviour, the ASA upheld the complaint and told the operator that the ad must not appear again in its current form and that future promotions must not encourage irresponsible behaviour.
William Hill: voucher not ‘designed to drive repeated play’
The voucher was issued to customers who deposit £50 or more on an eligible gaming machine before 5:20pm on the day that the promotion is issued and valid. This figure is the total value placed in-store, including a customer’s original cash-in and subsequent winnings played again.
Evidence was provided by William Hill to the ASA that the average cash-in in relation to the three-day promotion was “below the average spend for April and May 2025”. Therefore, the operator felt the amount that must be spent “to qualify for the promotion was substantial, nor that the promotion encouraged excessive staking”.
As it was a £5 voucher and could be spent on any game, the operator believed the promotion was “a low-value, one-off reward” and didn’t “involve any progressive elements, wagering multipliers, or additional conditions beyond what was initially displayed”.
William Hill noted it was “not part of a broader incentive structure nor designed to drive repeated play”, adding that the promotion’s terms, including the staking threshold and the redemption timeframe, were “clearly and fully” communicated to customers, and they were “given sufficient information to make an informed decision before participating”.
In addition, key qualifying conditions were “displayed on digital promotional screens in the shop and the voucher reiterated those eligibility conditions”, with the voucher serving as a “confirmation of eligibility which reminded consumers of the pre-disclosed redemption timeframe”.
William Hill also argued that the voucher’s redemption was entirely optional and that customers were free to not redeem the voucher or return later the same day. The operator supplied data too, showing that most customers who qualified for the voucher didn’t redeem it, which they believed demonstrated that customers knew redemption was optional.
The operator described the £5 voucher as ‘modest’ value and “did not believe that at any stage the promotion encouraged a customer to remain on the premises to engage in excessive consumption, nor encouraged irresponsible use”.
Although the promotion began at a later time than when the voucher was awarded, William Hill stated that it “did not encourage participants to remain on the premises and therefore it did not create any time-sensitive pressure to continue playing”, adding that very few customers redeemed the voucher within two hours, with most waiting three hours.
The operator said that the extended time between the voucher being issued and redeemed “strongly indicated” that most customers left and returned later to redeem the voucher, undermining the suggestion that the redemption window “pressured customers to remain in-shop or extend their play”.
William Hill added that any concerns regarding customer behaviour would have been met with a response in line with their polices, as all staff in their shops have received training to identify signs of gambling-related harm, and gaming machines provide prompts to remind customers of their time and money spent and allow customers to set limits.
ASA calls voucher ‘irresponsible’
Acknowledging the operator’s point of view, the ASA has upheld the complaint against William Hill since the timeframe of when the voucher is issued and redeemable “created an incentive for repeated play within a short period, including visiting the betting shop twice in a single day, increasing the risk of consumers gambling more than they otherwise would”.
Since the redemption period was at a later point in the day, the authority noted that participants could only benefit if they returned to the premises or stayed until the start time of the promotion, and that those eligible for the voucher may have already placed several bets earlier the same day.
“We thus considered that linking the reward to a same-day timeframe, particularly at a limited period later on the day, incentivised behaviours that could encourage irresponsible use,” the ASA stated.
“For those reasons, we concluded that the promotion encouraged irresponsible use and breached the Code”, particularly CAP Code (Edition 12) rule 8.5 (Protection of consumers, safety and suitability).
William Hill was told by the ASA that the advert must not appear again in the form complained of and that future promotions must not encourage irresponsible behaviour.
