As advertisers seek to reach the correct audiences with the right messaging, the legal framework has been designed to protect minors from potentially harmful content, especially in the context of digital advertising where targeted ads can easily reach unintended viewers. This article outlines the key rules and considerations for platforms, publishers, media owners, intermediaries, ad tech companies, agencies, and influencers on responsibly reaching adult audiences.

What ads are subject to age restrictions?

In the UK, there are sector specific rules on the advertising and marketing of age-restricted products such as alcohol, tobacco, food and soft drinks high in fat, salt, or sugars (HFSS), and gambling, which is strictly regulated to protect children. The CAP code restrictions apply to particular categories of products irrespective of the content of a marketing communication or the context in which they appear and splits its guidance regarding children into two categories, which are:

1. Under-18s protection: Ads for products like alcohol, cosmetic interventions, gambling, and weight reduction services should not be directed at individuals under 18. This includes avoiding media platforms where more than 25% of the audience is under 18.
2. Under-16s protection: For items such as HFSS food and drinks and certain gaming services, the ads should not target or be placed where more than 25% of the audience is under 16.

Protecting children sits at the heart of the ASA’s codes, as they cite that children are less well equipped to understand and process commercial messages in adverts, than adults. Advertisers are therefore advised to complete their due diligence on the restricted product and audience profiles of any media they plan to advertise in, to satisfy themselves that they are not at risk of targeting the wrong age group.

Media Restrictions

The Code has three key implications for different approaches to ad placement:

• No age-restricted ads should appear in or around media obviously directed at the protected age category irrespective of the method of targeting.
• For untargeted advertising, marketers must not place ads alongside media where the protected age category is likely to make up more than 25% of the audience.
• Where marketing communications are directed at audiences based on data held by the marketer, media owner and/or other third party, targeting measures must be used to minimise the likelihood of those in the protected age category from receiving them.

The core standards of identifying and delivering ads to audiences are consistent across all forms of non-broadcast media.

How can ‘advertisers’ use tools to target?

Generally, to comply with the restrictions and avoid appealing to a younger audience than intended, advertisers are expected to effectively use audience targeting tools available on digital platforms. For example, those tools include age-specific and interest-specific targeting features on social media platforms. By using these tools, advertisers can appropriately select audiences by age, interests, and other demographic factors to minimise the risk of exposing age-restricted ads to younger users. The ASA have upheld rulings where advertisers have not correctly used platform tools, see Just Eat.co.uk Ltd - ASA | CAP and Hollywoodbets International UK Ltd.

Advertisers should consider how to adopt best practices, such as:

• Understand the target audience: Clearly define the target demographic for age-restricted products. Ensure that a substantial number of the audience is of the legal age for the product being advertised.
• Use data responsibly: Leverage audience data analytics to refine targeting but avoid using sensitive data that could lead to non-compliance.
• Platform policies: Adhere to specific policies set by advertising platforms. For instance, major platforms like Meta and Google have additional rules regarding the promotion of age-restricted products.

How to approach content restrictions

Gauging the right tone and message of advertised content for an age-restricted product is a balancing act and as such, ads should not appear in content directly aimed at protected age groups. This includes any media specifically targeting children or teens, such as popular video games, children’s shows, or social media influencers with a young following. The ASA assesses each campaign based on the content around which the ad appears and the estimated audience composition. Therefore, a conscientious ‘advertiser’ will consider:

• Responsible Messaging: Ads must promote responsible consumption and avoid portraying the restricted products in a manner that could appeal to minors.
• Clear Labelling: Age-restricted products should be clearly identified as per their restrictions, with appropriate disclaimers applied to reinforce responsible messaging.
• Avoiding contexts that appeal to minors: By choosing media platforms that are age-appropriate, it provides a degree of comfort that the ad will target a predominantly adult audience.
• Timing: Consider the timing of ads, avoiding placement during programming or events popular with underage viewers, such as daytime children's programming, or seasonal holiday programming.

Collaborating with third parties

The CAP Code advises that advertisers should incorporate an understanding of the Code’s requirements into their compliance processes and campaign planning to avoid breaching the Code. It’s essential for all parties involved in developing and publishing a campaign – for instance, agencies, influencers and affiliates to be aware of, and follow the requirements of the relevant restrictions as they work to reach audiences online and have a clear understanding of their responsibilities regarding compliance.

When working with an influencer, the advertiser must check the influencer’s primary audience demographic to ensure that the influencer’s content is not predominantly viewed by individuals under the restricted age. Partnering with an influencer who primarily appeals to a young audience for an age-restricted product could be seen as a breach of the CAP Code, and both the advertiser and influencer could be held accountable by the ASA. The ASA’s ruling in Heineken Enterprise Ltd - ASA | CAP, demonstrates how the brand were able to successfully provide evidence that their ad was appropriately targeted, because they had data to show the influencer used did not have a following of more than 25% under 18s.

Ongoing monitoring

It’s best practice for advertisers to implement mechanisms to monitor ad placements, which could include regular audits of advertising content and targeting practices to stay compliant. Retaining records of the targeting methods and audience reach provides evidence if the ASA comes calling and shows that due consideration for the likely audience in each channel was taken. By following these steps and documenting efforts, brands and advertisers not only safeguard themselves against an adverse ruling by the ASA but also foster responsible advertising practices that protect vulnerable viewers.

Age checks

Advertisers need to be aware of how the regulatory environment is evolving, such as the obligations for platform providers to comply with mandatory age assurance checks under the Online Safety Act 2023 for specific online services that offer age-restricted content. Both Ofcom and the ICO wrote to tech platforms to tell them to make sure that children cannot access age-inappropriate content. Both regulators have been investigating several platforms for failure to implement robust highly effective age assurance and have published a joint statement on their approach. In addition the UK government is consulting on children’s wellbeing online, with possible stricter age checks being required as a result.

Conclusion

The responsible advertising of age-restricted products in the UK requires a comprehensive effort that demands careful planning, thorough audience analysis, and consistent monitoring.  It will be imperative for stakeholders—from agencies to influencers—to understand the regulation and adhere to best practices in targeting, content creation, and placement. A success advertiser will effectively promote responsible consumption and protect vulnerable audiences while maintaining the integrity of the brand.

If you advertise to consumers in the EU, it’s worth knowing that the European Commission launched guidance on age verification in 2025 along with a prototype of an age verification app, and we await the Digital Fairness Act later in 2026 which will also aims to deal with problematic content targeting children.