Bingo and lottery advertisements are allowed to air on UK TV at any time of day. This differs from sports betting, casinos and poker rooms, which were prohibited from advertising on TV until 2007 and can now only do so after 9 pm. What changed? In 2007, the then-new Gambling Act allowed all gambling operators to run TV adverts (albeit under certain conditions). According to Ofcom research, this caused a 600% increase in ads between 2007 and 2013.
While all gambling sectors and operators are subject to strict “social responsibility” advertising rules as part of their licensing conditions (these include ensuring adverts do not encourage irresponsible gambling behaviour, follow consumer law and do not target vulnerable players), only bingo and lottery operators are party to the Gambling Industry Code for Socially Responsible Advertising. The code includes rules regarding when adverts can be shown, including a pre-watershed ban and no ads in-between programs aimed at younger audiences. So why is it that bingo and lottery have different rules when it comes down to TV advertising?
Are lottery and bingo games considered gambling?
One of the key elements in answering this question is looking at the definitions of the lottery and bingo. Interestingly, bingo was the only form of legal gambling not defined in the 2005 Gambling Act. Since, the UKGC has issued further guidance, calling both games “equal chance” and even equating bingo to the lottery, defining it as “essentially a lottery played as a game”.
While the UKGC draws a clear difference between these types of gambling and others, such as games of chance and skill, it still counts them as gambling. However, the “equal chance” element is crucial. Unlike casino games and sports betting, these games offer pooled prizes with no listed payouts. Instead, each ticket issued has random numbers and the same chance of winning. In most cases, the prize pot is collected from the sale of tickets. Additionally, unlike other forms of gambling, smaller bingo and lottery games are allowed for charitable fundraising without licensing.
Lottery: A long history, state-franchised and a charitable affair
The lottery and bingo hold a historical legacy with British players either as a form of entertainment and community gathering or as a means of collecting money for charity; this is particularly clear for the lottery.
The UK lottery was established to raise state funds and organised by the government, with the first state-run games going back to the 16th century. In 1917 it was even used to raise money for the war effort and other good causes. By 1934, small lotteries were regulated, and in 1994 The National Lottery launched as a state-franchised operation with weekly games. As such, playing the lottery is a British staple, considered a charitable form of gambling and one under the remit of the government.
On the other hand, Bingo has long been considered a form of low-cost entertainment that became widely popular in the 1960s after the 1961 Betting and Gambling Act regulated bingo games and halls, casinos, and other forms of gambling. What’s more, the legal age to buy a lottery ticket is 16, while other gambling activities are restricted to those over 18s; this again reinforces the fact that these games are not characterised in the same way as the casino and betting industries.
Bingo in stats: A form of low-cost entertainment
Industry revenue statistics reveal more about why these two forms of gambling are characterised differently. According to The UK Gambling Commissions’ Industry Statistics for May 2021 (accounting for April-September, 2020), online bingo generated a gross gambling yield (GGY) of £98.1m (compared with casino games which had a GGY of £1.9bn and remote betting at £1.0bn).
From the online figures (in-person data is not included due to the closures caused by pandemic restrictions), it’s clear that bingo generates much less revenue than other forms of internet gambling. This is partly due to the lower cost of bingo tickets than other forms of gambling, like slot games or table games. It may be that this, along with the pooled prize pots, equal chance of winning the game, and historical legacy as a form of entertainment and communal activity rather than a form of winning money, has led to it being interpreted as a less-risky form of gambling.
Interestingly, for the same period, National Lottery tickets totalled £3.9bn, an equivalent of £1.6bn GGY, making it the second-largest gambling sector in the UK. Of this revenue, £775.1m was donated to good causes. These figures reinforce connotations of the lottery’s charitable status rather than a form of hard gambling.
No wagering bingo: Are bingo operators more responsible?
While the lottery continues to be state-franchised and used to generate funds for good causes, bingo nowadays is an open market with multiple licensed online and in-person operators providing the game. As such, it’s more complex to understand why it has different advertising rules, other than its definition as a game of equal chance.
It is possible to draw differences between bingo sites and other online casinos/sports betting sites. With players spending less, it could be argued that there are fewer incentives for operators to behave questionably. For example, the VIP scheme scandal, which saw players encouraged to join casino VIP schemes and deposit large amounts for better rewards without affordability checks, was generally not applied at bingo sites as players have a lower average spend; hence such schemes are not typical.
For the same reason, bingo sites tend to offer lower value bonuses, and bingo sites with no wagering are readily available, which is not always the case with online casino or sports betting bonuses. This is evidenced by a growing number of affiliates and operators advertising and providing bingo promotions that avoid using wagering requirements, which better suit lower budget players and do not encourage excessive gambling. Overall, this could attribute to the view of bingo as a safer, less risky form of gambling or a game played for entertainment value rather than the expectation of winning.
This is not to say that the UKGC doesn’t appropriately regulate bingo sites; they do, which can be seen in the case of Gala Bingo. In 2017, a Gala TV ad was banned by the UKGC as it did not adhere to the social responsibility code for advertising. The advert suggested that playing real money bingo could be a way to escape depression, pay off debt and finance media bills.
The bottom line
Many cultural and historical factors, along with the payout structure and nature of both bingo and the lottery, have led to different definitions and a general view that these types of gambling are communal or charitable activities rather than forms of hard gambling. For these reasons, bingo and lottery advertisements are allowed on daytime TV, while other forms of gambling are restricted to post-watershed rules.
