Top 10 ASA rulings: Q4 2025

Here, we cover rulings on price comparisons, appeal to under-18s, environmental and medical claims, countdown timers and an ad wrongly suggesting a business was UK-based.

ASA ruling on Select Specs Ltd

• Date of ruling: 12 November 2025 

• Decision: Upheld 

• Number of complaints: 1

The ASA investigated TV and YouTube advertisements for Select Specs which claimed "10 pairs…for the price of 1 pair from the high street", and that £6 glasses were available. The complaint questioned whether the price comparison was misleading and verifiable, and whether the £6 pricing claim was misleading. Overlaid small print text set out some offer restrictions.

Select Specs argued that the ads made a general comparison against the high street rather than any specific retailer. They provided evidence of comparable glasses from three major high street retailers (including Specsavers) costing over £60. They explained that customers could purchase 10 pairs from Select Specs for £60 including delivery, each with different prescriptions, unlike high street 2-for-1 offers which usually require the same prescription for both pairs. They maintained that the on-screen text adequately disclosed the £12 minimum order requirement and delivery terms.

The ASA upheld the complaint, finding that consumers would immediately identify the comparison as being with Specsavers specifically, due to the green background with two overlapping circles resembling Specsavers' logo and the reference to their 2-for-1 offer. The ASA considered consumers would expect comparison against Specsavers' cheapest glasses. Since Specsavers offered glasses from £15, consumers could purchase four pairs for £60 with different prescriptions, meaning the claim falsely suggested a price advantage.

The ASA found the comparison was not verifiable. The CAP and BCAP Codes require comparisons with identifiable competitors to include, or direct consumers to, sufficient information to verify claims. Whilst the ads signposted to Select Specs' website, that page contained no price comparison information.

For the £6 pricing claim, the ASA considered consumers would understand they could purchase a single pair for £6. The £12 minimum order amount and £5.95 delivery fee on orders under £49 was important qualifying information. The minimum order amount appeared in small on-screen text, which was considered to be insufficiently prominent to counter the overall impression of the ad.

This ruling shows the ASA's strict approach to comparative advertising, requiring price comparisons with identifiable competitors to be non-misleading and verifiable, with prominent disclosure of any mandatory costs. This ad also raises questions under the new price transparency obligations in the Digital Markets, Competition and Consumers Act 2024 (DMCC) (read our article on that here) given that the glasses could not actually be purchased at the advertised price. That issue is out of the scope of this ruling.

ASA ruling on Sky Bet

• Date of ruling: 22 October 2025 

• Decision: Upheld

• Number of complaints: 1 

The ad complained of was a promotional tweet by Sky Bet featuring Gary Neville discussing Premier League title predictions in a video from The Overlap football podcast. The complaint challenged whether the ad included an individual likely to be of strong appeal to under-18s.

Sky Bet argued that Neville did not hold strong appeal to under-18s, emphasising that he had retired from football in 2011 and last played for England in 2007 so met the "long retired" definition. They accepted he is now recognised as a football pundit, political commentator and businessman, but highlighted that only 1% of his 5.5 million X followers are aged 13-17 and that his TV appearances are mainly on late-night programmes targeting adult audiences. The tweet had also been targeted at users over 25 with an interest in sport.

The complaint was upheld. While acknowledging Neville's punditry career and media profile would place him in the "moderate risk" category, the ASA found that approximately 135,000 of his followers across X and Instagram were under 18, which was a significant number in absolute terms, even if the overall percentage was minimal. The ASA considered choosing to follow a personality on social media was an active act showing interest, and concluded that this indicated Neville's inclusion made the ad of strong appeal to under-18s.

This shows the weight that the ASA gives to metrics such as the number of under-18 followers when determining whether there is appeal to minors and appears to be a deviation from the assumption that a low percentage of the audience who are under-18 is indicative of not being of appeal to minors. That assumption can be rebutted where the figure has a large number of followers, such that even a small percentage of their audience equates to a significant sized audience.

ASA ruling on Red Tractor

• Date of ruling: 15 October 2025 

• Decision: Upheld 

• Number of complaints: 1

A TV ad for Assured Food Standards' Red Tractor Scheme, which stated, "Farmed with care, that's the Red Tractor way" and "from field to store all our standards are met" was considered by the ASA. The complaint challenged whether the ad overstated the benefits of Red Tractor endorsement, citing Environment Agency reports that suggested pollution-related environmental breaches on Red Tractor Assured farms.

Red Tractor explained that their scheme concentrates on farming practices, animal welfare and food traceability, conducting independent farm inspections every 12-18 months with 98% compliance rates. They contended that consumers would not view their advertising claims as relating to environmental matters.

The complaint was upheld, being found to likely overstate the benefits of Red Tractor endorsement. The ASA found that a significant minority of consumers would reasonably expect that claims about high farming standards would include environmental risk management, recognising the connection between quality food production and environmental management. Consumers would also anticipate that the standards would meet or exceed basic legal environmental requirements.

It was accepted that consumers would not understand "all our standards are met" as an absolute guarantee of constant 100% compliance. Environment Agency data from 2014-2024 revealed approximately 50% of inspected Red Tractor farms failed to fully comply with various environmental regulations. The ASA concluded that whilst Red Tractor demonstrated an extensive process for compliance with their own standards, evidence of compliance with basic legislative environmental standards was insufficient to substantiate the wider claim conveyed by "farmed with care…all our standards are met".

This ruling shows that when considering environmental claims broad interpretations may be considered, even if only a minority would interpret the claims in that way. It is also important that when 'standards' are referred to in ads, it is clear which standards are being referred to and the extent to which they are being met.

ASA ruling on Hammonds Furniture Ltd

• Date of ruling: 8 October 2025 

• Decision: Upheld 

• Number of complaints: 1

The ASA investigated a Hammonds Furniture banner ad featuring a countdown timer stating, "Up to 40% off selected finishes + an extra 5% offer ends in […]", and the claim "We won't be beaten on quality and price". The complaint challenged whether:

• the countdown clock was misleading

• the price claims were misleading and could be substantiated

• the price claims were verifiable.

Hammonds stated that the countdown timer related only to the "extra 5%" offer, which they believed consumers would understand. For the price claims, they believed consumers would understand these to refer to their price match promise and provided spreadsheets detailing price match claims and market checks conducted between June 2024 and August 2025.

The complaint was upheld. The countdown clock was misleading because the banner ad presented the text as a continuous sentence without indicating that there were two separate offers, leading consumers to believe one combined promotion was ending with the countdown. The countdown was likely to pressurise consumers into swift purchasing decisions, so the ad was found to breach the CAP Code. The CMA also takes a dim view of the use of misleading countdown timers and similar pressure-selling tactics, as indicated by the undertakings obtained from Wowcher and Simba Sleep.

The ASA concluded that consumers would understand the price claims as meaning Hammonds Furniture offered cheaper prices than competitors, rather than as a reference to a price match promise, as the ad made no such reference. The price match spreadsheet was insufficient to substantiate the lowest price claim, with only seven price checks against a single competitor deemed inadequate. Hammonds' bespoke products also meant that any comparative price claims would be particularly challenging to substantiate. Hammonds should have instead referred to the price match promise within the ad to make their claim clear.

The price claims were also unverifiable, with the ad giving no information for consumers to check the claims.

This decision shows the ASA's strict approach to promotional countdown timers and how comparative price claims require robust substantiation and verifiable information.

ASA ruling on Shell Energy UK

• Date of ruling: 1 October 2025 

• Decision: Not Upheld 

• Number of complaints: 1

This ruling forms part of the ASA's ongoing scrutiny of environmental claims in adverts, particularly relating to energy sector "greenwashing". It is a rare example of an environmental claim that was found not to mislead. A LinkedIn advert featured a video showing solar imagery alongside text describing the company's collaboration with Baker Hughes on energy requirements and decarbonisation. The complaint questioned whether the ad created a false impression of Shell's overall environmental performance.

The ASA acknowledged that the ad could reach both consumer and business audiences on LinkedIn, but the prominent Shell Energy branding combined with content about commercial services unavailable to general consumers established it as a B2B communication.

The complaint was not upheld. The ASA found that viewers would interpret the advert as a specific example of Shell Energy assisting commercial clients with decarbonisation, rather than as a statement about Shell's broader consumer brand or its own climate commitments. The ASA found that the foundation of the environmental claims was transparent and unlikely to deceive.

This ruling shows the ASA's differentiated approach to environmental claims in B2B contexts, accepting that specific client case studies can be separated from wider corporate environmental statements when the framing is sufficiently clear. Whereas the ASA has previously established that it takes a very strict approach to environmental claims in B2C advertising.

ASA ruling on Au Vodka Ltd

• Date of ruling: 24 September 2025 

• Decision: Upheld 

• Number of complaints: 2 

This ruling forms part of the ASA's ongoing enforcement work on alcohol advertising, particularly concerning age-appropriate targeting and the use of young influencers. The investigation examined three different social media adverts, all of which showed a young person drinking a can of Au Vodka Juicy Peach. The complaints challenged whether the first advert, which featured a former Love Islander, was inappropriately targeted at under-18s, and whether the other adverts featured individuals under 25.

The CAP Code sets out two key requirements: alcohol adverts must not be aimed at under-18s, and no medium should be used where more than 25% of the audience is under 18. Additionally, people shown drinking or playing a significant role in alcohol ads must not be, or seem to be, under 25.

The complaints were upheld. For the ad featuring the former Love Islander, Au Vodka provided demographic data of her TikTok followers, but this did not include the number of followers aged between 13-17, thereby preventing verification that less than 25% were under 18. Given TikTok's algorithm and her association with Love Island, which Au Vodka acknowledged primarily appeals to 16-34 year olds, the ASA concluded that under-18s were likely to see her post through TikTok's recommended algorithm, even without following her.

The second ad was geo-targeted to US audiences, but the ASA found it to be visible to UK consumers and so subject to the CAP Code.

Au Vodka acknowledged that the third ad was a breach, as it featured a 24-year-old, describing it as an oversight, and confirming that more stringent internal compliance checks were being implemented.

This ruling underscores the strict requirements for alcohol advertising, particularly the prohibition on featuring anyone who is, or appears to be, under 25. It also confirms that geo-targeting intentions are irrelevant if UK consumers can access the content.

ASA ruling on Marble Muse

• Date of ruling: 24 September 2025 

• Decision: Upheld 

• Number of complaints: 1

The website of Marble Muse, a clothing company, featured imagery with a British aesthetic, including London street backdrops. The homepage displayed "BRITISH BRAND" with a Union Jack, referenced being "founded in London" and listed a London address. The complaint challenged whether the website misleadingly implied the company was UK-based.

The CAP Code requires that marketing communications must not mislead by omitting material information. In this scenario, material information included the company's identity and address.

The complaint was upheld, finding that consumers would reasonably interpret the website as indicating that the company was UK-based when this was not the case.

This ruling reinforces the ASA's position that brands cannot use imagery and symbols to create a false impression of a particular geographic origin, misleading consumers, and must provide transparent information about their actual business location.

ASA ruling on Midnite

• Date of ruling: 17 September 2025 

• Decision: Upheld 

• Number of complaints: 2 

This ruling against Midnite represents the ASA's continued scrutiny of gambling adverts on social media platforms, particularly concerning the protection of under-18s. The ad was a post on Midnite's X page featuring an AI-generated video of Trent Alexander-Arnold giving a fictional farewell speech to Liverpool players. The post included disclaimers that it was an "AI-generated parody" and featured safer gambling messaging, but the complaints queried whether the ad included a person likely to be of strong appeal to under-18s.

In response, Midnite argued the post was editorial content rather than advertising. The ASA concluded that as the post featured prominent Midnite branding, including gambling-related messaging and was published during Alexander-Arnold's high-profile transfer to Real Madrid, its purpose was to promote the brand through viral content and was directly connected with the supply of betting services.

The ASA assessed whether X's age-verification measures sufficiently excluded under-18s from the audience. X prevents known under-18s from following gambling accounts or seeing gambling-related content, but this relies on self-verification at sign up, rather than more stringent age assurance or age verification methods. This means that a significant number of children could access content intended for adults, and therefore under-18s were not effectively excluded from the audience.

The complaint was upheld, finding that Alexander-Arnold was likely to be of strong appeal to under-18s due to playing for Liverpool and the English national team. Although the imagery was AI-generated and labelled as such, it was clearly recognisable as depicting him.

This ruling shows that gambling operators cannot avoid advertising rules by labelling content as "parody" when it prominently features their branding and gambling messaging, the ASA will assess the objective purpose of the content which, in this case, was deemed as promotional. Crucially, the use of AI-generated content does not diminish the appeal of the depicted individual to under-18s. Advertisers also need to be conscious that current social media age-verification measures do not adequately exclude under-18s from viewing gambling content.

ASA ruling on Scar Erase

• Date of ruling: 17 September 2025 

• Decision: Upheld in part 

• Number of complaints: 1

The ruling concerns an Amazon listing for silicone scar sheets that made claims including being "clinically proven" to reduce scar appearance. The ad also stated scars could be minimised "AS FAST AS 6 WEEKS" and featured before and after images showing complete scar removal. The complaint challenged the medical claims as well as the claims surrounding efficacy and timeframes. The authenticity of the images was also questioned.

The complaint regarding the medical claims was not upheld, as the product was correctly registered with the MHRA and held appropriate conformity markings, meaning such claims were permitted.

The complaint around the efficacy claims was upheld. Scar Erase submitted various studies to substantiate the claims, but these were found to be lacking, due to having insufficient sample sizes, lacking control groups, being unpublished or unreviewed studies, and relating to similar, not identical, products. The ASA considered these format differences clinically relevant, making the evidence inapplicable to the advertised product.

The images were found to be misleading with consumers likely to interpret them as genuine results, despite the presence of a disclaimer. No evidence had been provided to show that the images were authentic or representative of typical outcomes.

This ruling highlights that supporting clinical evidence must directly relate to the specific product being advertised, not merely similar products or formats and the studies relied on for substantiation must be high quality and reviewed. Disclaimers cannot remedy misleading visual claims, and any efficacy or timeframe claims require robust studies with adequate sample sizes.

ASA ruling on cruise 1st

• Date of ruling: 3 September 2025 

• Decision: Upheld 

• Number of complaints: 1

This ruling forms part of the ASA's ongoing work in relation to "greenwashing". A website for 'Cruise 1st' claimed the ship MSC World Europa was "Powered by LNG, the world's cleanest marine fuel", "uses new green technologies" and offers a "green alternative" for environmentally conscious consumers. The complaint challenged whether the ad gave a misleading impression of the cruise ship's environmental impact.

The CAP Code requires that environmental claims must be clear, with absolute claims supported by a high level of substantiation.

The ASA considered that consumers would interpret the ad as meaning MSC World Europa would have a lower environmental impact compared to other cruise operators. Evidence to support the absolute claims had not been provided. Whilst LNG produces lower emissions than traditional marine fuel when burned, its production and use have other negative environmental impacts. The ad failed to explain LNG's significant CO2 emissions over its full life cycle (including during its extraction and refining). Due to the insufficient context and lack of substantiation, the ASA held that the ad exaggerated the ship's environmental credentials and was likely to mislead.

This ruling shows the ASA's requirement that environmental claims must be properly contextualised and substantiated with reference to full life cycle impacts. Even where a product may be less harmful than alternatives, it cannot be presented as environmentally friendly without acknowledging ongoing negative impacts. It is also worth noting that 'Cruise 1st's position as an agency using content from official sources did not absolve them from responsibility for ensuring claims were accurate.