Advertising and Marketing | UK Regulatory Outlook October 2025

UK updates 

ASA publishes report on use of AI to assess ads for alcohol  

The Advertising Standards Authority (ASA) has deployed its AI-based Active Ad Monitoring System to analyse alcohol ads online against section 18 of the CAP Code, which sets out alcohol-specific rules. The ASA captured and processed nearly 6,000 UK paid-for ads from early 2025. Overall, compliance levels were high: 96% of ads were assessed as likely compliant with the CAP Code, with only 1-3% assessed as likely non-compliant and the remainder as ambiguous, requiring further investigation. 

The ASA concluded that large language models (LLMs) can be used effectively to assess sector-specific ads at scale and that LLMs can help the ASA spot potential issues in instances where there are no complaints, but where there could still be an impact on consumers or vulnerable groups. 

The trial has also given the ASA technical insights, which will shape how it applies AI in future work across other sectors. In particular, the ASA will explore: 

• Integrating human feedback into LLM prompting, so that assessments more closely reflect expert interpretation of the CAP Code.
• Incorporating additional ASA guidance, such as AdviceOnline articles, into the context, helping the LLM better understand how rules are applied in practice.
• Improving the LLM's understanding of the ASA's enforcement priorities, such as weighting results based on likely harm, reach or impact.
• Linking ads from the same campaign, so that the ASA can review messaging in context and avoid duplication of effort.
• Experimenting with newer models and more advanced prompting methods to improve accuracy and reduce false positives. 

Advertisers should be aware that the ASA is increasing the use of its AI tool across various sectors to identify, at scale, ads that potentially do not comply with the CAP Code. As the ASA perfects its approach, advertisers should expect it to pick up and potentially take action against more ads in the future. 

CAP and BCAP update guidance on protecting under-18s in gambling and lotteries advertising 

CAP and BCAP have updated their guidance on protecting under-18s in gambling and lotteries advertising, clarifying how the "strong appeal" test should be applied. The updated guidance adds a rule-of-thumb metric for social media followers and distinguishes "adult-centric" and "non-adult-centric" sports, so that advertisers can strengthen their compliance.  

See our Insight for more information and possible practical steps for gambling operators and their marketing agencies to take as a result of this updated guidance. 

CAP updates guidance on age-restricted ads online 

CAP has updated its guidance on responsible targeting of age-restricted ads online. The new version has been made easier to use and now includes a two-page summary of the fundamentals of responsible targeting, alongside a contents page to help readers quickly find the information they need. The text has also been streamlined to cut down on repetition. Other updates include adding material reflecting recent findings on how age-restricted ads can appear in unsuitable places online and clearer references to influencers and content creators, as well as corrections to outdated or inconsistent terminology.  

The guidance is essential reading for advertisers involved in campaigns for age-restricted products. Advertisers should also be aware that the inclusion in the guidance of recent findings on age-restricted ads appearing in unsuitable places online, and references to influencers and content creators being made clearer, reflects the ASA's increased scrutiny of, and enforcement against, these types of advertising and advertising compliance issues. 

Updated enforcement notice on weight-loss prescription medicine ads 

CAP, jointly with the Medicines and Healthcare products Regulatory Agency and the General Pharmaceutical Council, has issued an updated enforcement notice on ads for prescription-only weight-loss medicines. The notice reminds marketers that advertising prescription-only medicines (POMs), including those used for weight management, is prohibited. 

The notice prompts advertisers to review their ads in accordance with the guidance set out in the notice and remove from their ads all named POMs, descriptors and imagery that are likely to be understood by consumers as referring to POMs, as well as links to landing pages that promote them. 

The notice also reminds advertisers that the ASA's AI-assisted Advice Ad Monitoring system is in use to actively scan for ads that breach the notice and that this may result in sanctions. The ASA has, in fact, already taken action against nine advertisers in this area – see this MarketingLaw article for further information.  

EU updates 

Regulation on the transparency and targeting of political advertising comes into effect 

The Regulation on transparency and targeting of political advertising (EU/2024/900) became fully effective on 10 October 2025 and, just before that date, on 8 October, the European Commission published guidelines to support implementation of the regulation. 

The regulation harmonises rules on political advertising across the EU, from preparation to dissemination, for political advertising publishers and providers of political advertising services, which includes political consultancies, advertising agencies, "ad-tech" platforms, influencers and website and app publishers. It does not ban political ads, or regulate their content, but sets out requirements around labelling, transparency notices, targeting and record-keeping. 

The main requirements for political advertising services include: not discriminating against sponsors, preventing foreign interference, undertaking due diligence, ensuring transparency, record-keeping, transmission of information, and targeting and delivery techniques. 

In the context of online political advertising, targeting or ad delivery techniques involving the processing of personal data is only permitted where: the controller collected the personal data from the data subject; the data subject provided explicit consent for the purpose of political advertising; and the targeting techniques do not involve profiling using special categories of personal data (such as data on political opinions). In addition, controllers must: publish an internal policy on the targeting techniques used, keep records of the use of such techniques, and provide additional information for each political advertisement that allows individuals to understand the logic and main parameters of the techniques used, including whether an AI system is involved. 

There are also additional requirements for political advertising publishers: all political ads have to be clearly labelled as such and be accompanied by information about sponsors (that is, who paid for them and how much), the linked election/referendum/legislative or regulatory process, and whether they are targeted toward a specific audience. Political ads must also include an easily retrievable transparency notice, providing certain key information. In July 2025, the European Commission adopted an implementing regulation on the format, template and technical specifications of such labels and transparency notices. 

Member States have until 10 January 2026 to lay down rules on sanctions for infringements of the regulation (apart from those relating to targeting). For infringements relating to targeting, data protection supervisory authorities may impose fines under the General Data Protection Regulation. See this Insight for more information. 

As for the guidelines, they are designed to provide practical guidance and explanation to assist those in scope of the new rules. For example, they include information on how to identify a political ad and how to comply with due diligence obligations.