Listen to this article:Buzz Bingo has been cleared by the Advertising Standards Authority (ASA) after two complaints were submitted regarding a Facebook post by Buzz Bingo that featured an AI-generated action figure. The ad, posted by Buzz Bingo Grimsby in April, led to concern that it might appeal to under-18s.
The image, created in the style of a popular “starter pack” AI trend, depicted a cartoon woman inside an action figure-style box labelled “[NAME] ACTION FIGURE”. The accompanying items inside the box were a bingo dabber, bingo cards, and a numbered bingo ball, all of which are objects clearly associated with bingo rather than children’s toys.
The post included the caption:
“For a limited time only, Buzz Bingo Action Figures (crying laughing face emoji). Only available at Buzz Bingo Grimsby! (eyes emoji) T&Cs Apply. Play Together, Safely. Over 18s Only.”
It also included a link to Gamble Aware, indicating the company’s effort to promote responsible gambling.
The complaints alleged that the use of an action figure might make the post appealing to minors. However, Buzz Group, the parent company of Buzz Bingo, explained that the image was generated using AI and was modelled after the General Manager of the Grimsby club. It was not based on a celebrity or a known public figure, and the character wore office attire with muted colours and no exaggerated features.
Buzz also clarified that the ad was visible only to followers of the Buzz Bingo Grimsby Facebook page, where users must self-identify as being over 18.
In its ruling, the ASA stated:
“We considered that action figures or dolls were likely to appeal to some under-18s. However, we considered that despite the image being computer-generated, the overall style of the ad was realistic rather than cartoon-like. The figure depicted was an adult who did not have exaggerated features, was wearing a simple shirt, and was not a recognisable or well-known character.
“The colours were muted rather than bright and were not reminiscent of dolls or action figures that were typically marketed towards children. We considered that the ‘action figure’ depicted was unlikely to be viewed by children as an appealing toy to play with.”
“We therefore concluded that the ad was not likely to be of strong appeal to those under 18 years of age.”
This ruling contrasts with a recent ASA decision involving Ladbrokes’ “Ladbucks” campaign, which was found to breach advertising rules due to its strong appeal to minors. In that case, the regulator upheld two complaints against TV and Video on Demand ads that promoted a rewards scheme resembling popular in-game currencies.
The “Ladbucks” tokens, depicted as stylised coins marked with “Lb”, were deemed visually and conceptually similar to youth-oriented virtual currencies such as V-Bucks and Robux, used in games like Fortnite and Roblox. The ASA cited research showing these elements were likely to resonate with under-18s, and concluded that the ads violated BCAP and CAP rules. As a result, the campaign was banned, and Ladbrokes was instructed to avoid future content that might reflect youth gaming culture.
In contrast, the ASA determined that Buzz Bingo’s action figure ad avoided bright colours, cartoon-like design, or pop culture references that might attract underage users. The responsible use of the trending AI format and restricted audience ensured Buzz Bingo did not break any rules.
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