Staying onside: rules for World Cup-related promotions

If you are planning a World Cup-related advertising campaign or prize promotion this summer, be careful not to fall foul of the rules.

The Advertising Standards Authority (ASA) published a useful guidance note on this subject last month. While parts of the guidance are specific to the World Cup (and in particular the requirements of FIFA) the general legislative and regulatory framework that governs advertising and promotion must also of course be taken into account.

Avoiding implied endorsement

You may make generic references to football and the tournament but your promotions must not imply an official association, sponsorship or endorsement if none exists.

Generic football references or puns are usually acceptable on their own, but combining elements that suggest an official link can be problematic.

FIFA maintains strict controls over the use of its intellectual property. Advertisers should familiarise themselves with FIFA’s Intellectual Property Guidelines (available on its website) and take appropriate advice if in doubt.

Gambling and alcohol in advertising

Football-related gambling ads must not feature individuals with strong appeal to young people and must not portray betting as a solution to financial concerns or a route to social or professional success.

Ads for alcohol or which feature alcohol should not:

• condone excessive drinking 

• suggest drinking in inappropriate situations

• imply that alcohol enhances sporting or physical performance 

Gambling and alcohol ads must not feature people who are (or appear to be) under 25 in significant roles. This is clearly a risk in the context of a tournament where many players are very young and globally famous.

Avoiding an illegal lottery

A prize promotion will be an unlawful lottery under the Gambling Act 2005 if there is payment to participate, a prize, and winners are determined by chance, unless a statutory exemption applies.

A promotion should either be structured as a genuine skill‑based prize competition (for which payment can be required to enter) or provide a genuinely free entry route alongside any paid method. 

The requirement to buy a product to enter a prize draw will generally not be considered a payment to enter, provided that the cost of the product has not been altered to reflect the opportunity to participate. Temporary increases in price or a reduction in quality or volume of a product during the promotional period should be avoided.

For a competition, the skill element must deter a significant proportion from entering and prevent a significant proportion of entrants from winning; answers should not be obvious or easily searchable.^. 

A free entry route can be via normal rate postage, standard‑rate calls or SMS, or website entry, provided it is prominently publicised and genuinely as accessible as any paid route.

Clarity and fairness in promotions

Under the codes published by the Committee on Advertising Practice (CAP) promoters must set out clearly the significant conditions of the promotion, including:

• how to enter

• any eligibility restrictions, for example age, geographical location, exclusions for employees of the promoter

• start/closing dates

• the number and nature of prizes

Where selection of a winner involves subjective judgment, an independent judge or a panel including an independent member must be appointed, and the names of the judges must be disclosed on request

If you’re planning any World Cup‑related advertising or prize promotions and want to ensure your campaign stays compliant, contact Catherine O’Riordan in our Commercial team. She can guide you through the rules and help you avoid costly regulatory pitfalls.

The contents of this article is a general guide only at the date of publication. It is not comprehensive, and it does not constitute legal advice. Specific legal advice should be sought in relation to the particular facts of a given situation.

This summer’s FIFA World Cup will place football firmly at the centre of public attention for several weeks, offering advertisers a huge opportunity to create timely, engaging campaigns. However, high‑profile international tournaments also raise familiar regulatory risks.

https://www.asa.org.uk/news/make-sure-you-don-t-need-var-keeping-your-world-cup-ads-onside.html