Advertising Standards AuthorityObjectification of WomenAdvertising Content Regulation

Advertising Compliance Risks for Games Going Global: The UK ASA Report Sounds the Alarm

游戏出海广告注意,英国 ASA 报告敲响广告合规警钟

January 15, 2026
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Summary

This article reviews a 2025 report issued by the UK Advertising Standards Authority on the sexualisation of women in in-app game advertising. Through multiple enforcement cases, it highlights common compliance risks in overseas game advertising, particularly where suggestive or sexualised content is placed in applications accessible to children. The article further outlines practical advertising compliance guidance issued by the UK Committee of Advertising Practice, providing concrete reference points for game companies conducting advertising campaigns in the UK market.

The UK Advertising Standards Authority (ASA) is responsible for ensuring that advertisements appearing in UK media comply with advertising rules. ASA maintains an active enforcement posture. In 2022 alone, ASA handled 33,350 complaints involving 21,955 advertisements. A number of game advertisements have previously been investigated and regulated due to non-compliant disclosures, including ads placed by companies such as EA and Hutch Games.

In March 2025, ASA released a report titled “Sexualisation of Women in In-App Game Advertising.” The report noted that although such advertisements were relatively rare, the content involved constituted serious breaches of advertising rules. Between 2023 and 2024, ASA handled 11 complaints relating to similar advertisements.

ASA conducted three months of monitoring on 14 game applications and found that non-compliant advertisements primarily involved the following types of content:

  • Harmful stereotypes portraying women as sexual objects.

  • Implications of sexual contact without consent.

  • Use of sexual innuendo.


Case One: Perfect Lie — Sexualised Advertising Placed in a Children’s Game App

Perfect Lie is a game that tests players’ ability to detect deception, rated PEGI 12. According to its rating information, the game contains sexual innuendo. However, advertisements for Perfect Lie appeared in My Talking Tom 2, a game featuring a virtual cat and rated PEGI 3.

The Perfect Lie advertisement included animated depictions of a student and a female teacher. The teacher approaches the blackboard and bends over, with her buttocks appearing pixelated. Two options are then displayed: “Look away” and “Watch her A**.” The second option is selected, followed by a text bubble stating “Did you just check me out?” The student character appears to be under the age of 18.

ASA determined that the advertisement clearly breached the Code, as the combined depiction and text involving a student and a teacher were likely to cause serious offence and potential harm.


Case Two: My Fantasy — Advertisements Containing Sexual Innuendo

My Fantasy is an interactive romantic story game rated PEGI 16, with rating information indicating the presence of strong violence, sexual nudity, and coarse language.

The My Fantasy app deployed two different advertisements targeted at female and male child avatars, respectively. These ads were placed in the following games:

  • Traffic Escape, a game involving freeing cars from traffic congestion, rated PEGI 3, which may appeal to a general audience including children and young people. Advertisements for My Fantasy appeared during gameplay.

  • Lamar – Idle Vlogger, a character simulation game rated PEGI 12 due to moderate violence, which may attract a general audience including older children and young people. Both My Fantasy advertisements were visible in this application.

The first My Fantasy advertisement depicts a woman being approached by another woman and pushed onto a table. The woman on the table moves rhythmically up and down from above, with her clothed breasts prominently emphasized on screen. Text reading “What should I do” appears alongside options “Enjoy it” and “Push her away.” Another woman then appears, moving in the same manner, accompanied by text “What should I do” with options “Stop it!” and “Please, continue……”

Although the content does not include explicit sexual imagery, it is highly suggestive and implies sexual contact that is not consensual. The second advertisement is very similar in content.

For these reasons, ASA concluded that the advertisements clearly breached the Code, as they were likely to cause serious offence, harmful sexual stereotyping of women, and potential harm.


Case Three: Linky: Chat With Characters AI — Advertisements with Suggestive Content

Linky: Chat With Characters AI is rated “Parental Guidance Recommended” on Google Play and “17+” on the Apple App Store. While the application itself contains sexual content, its advertisements were placed in the following two games that may appeal to children.

Although the advertisements for Linky did not contain explicit sexual depictions, they were suggestive in nature, implying violence, coercive control, and non-consensual scenarios.


Case Four: Love Sparks: Dating Sim — Advertisements Depicting Women in an Insulting Manner

Love Sparks: Dating Sim is a romantic chat and dating simulation application rated PEGI 16, containing nudity and coarse content. The advertisements for this product used sexual innuendo to depict women as stereotypical sexual objects and even included non-consensual scenarios. These advertisements were placed in game products targeting children and young audiences. ASA determined that such content was likely to cause serious offence.


Compliance Guidance Issued by CAP

Based on the above cases, although ASA itself does not possess mandatory enforcement powers, its sister organization, the Committee of Advertising Practice (CAP), issued specific guidance addressing these issues. For advertising materials placed in the UK, overseas game publishers should ensure that advertising content complies with applicable laws and regulations. In particular, publishers should pay attention to the following points:

  1. Prohibit content that encourages domestic violence, sexual assault, physical attacks, sexual acts, portrays women as potential victims of sexual assault, or depicts non-consensual behavior.

  2. Prohibit voyeuristic advertising and sexually suggestive content that objectifies female characters.

  3. Prohibit other forms of advertising content—beyond violence, objectification, and sexualization—that may cause harm or serious offence.

  4. Exercise caution to ensure that any violent imagery (even if reflective of in-game content) is not excessive or graphic; ensure that violence or weapon use is not glamorized or condoned. Avoid depicting weapons pointed directly at or aggressively toward the audience, as such imagery may be perceived as threatening and may cause unnecessary fear or distress.

  5. Game advertising content should reflect the actual product and showcase real gameplay. Where in-game footage is shown, it must be footage from the relevant game. “Cinematic representations” unrelated to actual gameplay are not acceptable.

中文原文

英国广告监管机构-广告标准局(ASA)负责确保英国媒体上的广告遵守广告规则。ASA执法活动活跃,2022年ASA处理了涉及21955条广告的33350起投诉。不少游戏广告也曾因广告内容披露不规范被调查管制,包括EA、Hutch Games等。《英国严查游戏广告合规,头部产品躺枪》《游戏广告披露信息不清晰 EA再次被调查》《英国下架5款模拟赌博游戏广告,如何避免产品宣传的合规雷区?》

2025年3月,英国ASA发布了《游戏应用内广告物化女性》的报告,其表示虽然这类广告比较少,但广告内容严重违反了规定。在2023年至2024年期间,ASA处理了11条类似广告的投诉。

ASA对14款游戏应用进行了为期3个月的监控,发现这类不合规广告涵盖以下内容:

  • 将女性作为性对象的有害刻板观念。

  • 暗示未经同意的性接触。

  • 使用色情暗喻。

案例一:Perfect Lie广告内容物化女性,在儿童游戏应用中投放 

Perfect Lie是一款测试用户欺骗骗子的能力,评级在PEGI 12,从评级信息来看该款游戏包含性暗示。但该款游戏的广告出现在My Talking Tom 2中。My Talking Tom 2则是一款以虚拟猫为特色的游戏,评级在PEGI 3。

Perfect Lie广告中包括对一名学生和一名女教师的动画描绘。老师走近黑板,弯下腰,她的屁股看起来像素化了。此时会显示两个选项:“Look away (移开视线)”和“Watch her A**”。第二个选项被选中,并出现一个文本气泡 “Did you just check me out?”该学生角色看起来未满18岁。

ASA认为,该广告内容明显违反《守则》,因为对学生和女教师的描绘与文本相结合可能会造成严重冒犯并有可能造成伤害。

案例二:My Fantasy广告内含性暗示内容

My Fantasy 是一款互动式浪漫故事游戏。它被 PEGI 16 评为 PEGI,指出该游戏包含强烈的暴力、性裸露和粗俗的语言。

My Fantasy 应用有两种不同广告,分别投放到女性和男性儿童头像,投放方式为:

  • Traffic Escape,一款涉及将汽车从交通拥堵中解救出来的游戏。评分为 PEGI 3 ,该应用可能会吸引普通受众,包括一些儿童和年轻人。在此应用进程中看到了 My Fantasy 的广告。

  • Lamar – Idle Vlogger ,一款角色模拟游戏。由于中度暴力行为,该应用被评为 PEGI 12 级,该应用可能会吸引包括一些年龄较大的儿童和年轻人在内的普通受众。My Fantasy 的两个广告都在此应用中可见。

而My Fantasy的第一个广告描绘一个女人被另一个女人接近并被推到桌子上。桌子上的女人从上方有节奏地上下移动,她穿着衣服的乳房在屏幕上特别突出。文本“What should I do”与“Enjoy it”和“Push her away”选项一起显示。然后,另一名女性以相同的方式移动,上面写着“What should I do”和“Stop it!”和“Please,continue……”选项。虽然内容没有露骨的性内容,但它具有强烈的暗示性,也暗示性接触不是双方自愿的。第二个广告的内容非常相似。

基于这些原因,ASA认为,广告内容明显违反了《守则》,因为这些广告可能会引起严重的冒犯,将女性有害地定型为性对象,并有可能造成伤害。

案例三:Linky:Chat With Characters AI投放广告带有暗示性内容

Linky:Chat With Characters AI在Google Play 的评级为“Parental Guidance recommended”,Apple App Store 评为“17+”。该应用程序包含性内容,但该应用的广告投放在以下两个可能面向儿童的游戏产品。

Linky产品的广告内容虽然没有直接的露骨性描写,但带有暗示性,隐含了暴力和胁迫性控制以及未经同意的情景。

案例四:Love Sparks:Dating Sim广告以侮辱女性的方式描绘女性

Love Sparks: Dating Sim 是一款爱情聊天和约会模拟应用程序,评级为PEGI 16,该应用含有裸体和粗俗内容。该产品广告中的女性都使用色情暗喻,将女性描述成刻板的性对象,甚至包含未经同意的情况。此类广告被投放在面向儿童和年轻受众游戏产品中。ASA认为广告内容引起严重冒犯。

结合以上案例,虽然ASA不具有强制性的执法权,但ASA 的姊妹机构广告实践委员会CAP就以上案例发布了具体的指南。针对英国地区投放的广告素材,出海厂商应该注重广告内容符合相关法律法规的要求。具体而言,出海厂商注意以下事项:

1.禁止包括鼓励家庭暴力、性侵犯、人身攻击和性行为、将女性描绘成可能遭受性侵犯的受害者以及描述非自愿性行为。

2.禁止包括性偷窥广告和物化女性角色的性暗示内容。

3.禁止发布除暴力、物化和性化之外的其他可能造成伤害和冒犯的广告。

4.谨慎确保任何暴力图像(即使反映游戏内容)不过度或露骨;应确保不美化或纵容使用暴力或武器。避免描绘直接指向或攻击性地指向观众的武器,因为此类图像可能被视为威胁,并可能引起不必要的恐惧和痛苦。

5.游戏广告内容应反映产品本身并展现游戏玩法。如果展示游戏内视频,则应为相关游戏的片段,不接受游戏主题的“电影表现形式”。

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