Independent Reviewer

In some circumstances, ASA rulings can be challenged by an advertiser or complainant when there is evidence that we have not got the decision right or there was a flaw in our processes. Find out more about the Independent Review process.

Sarah Munby

Independent Reviewer

Sarah’s career has spanned senior roles in both the private and public sectors. She's held leadership positions in government, most recently as Permanent Secretary of the Department for Science, Innovation and Technology, where she oversaw the UK’s approach to technological change, including developments in AI, online safety and scientific research. Prior to this, she was Permanent Secretary of the Department for Business, Energy and Industrial Strategy. Sarah has extensive experience of working with regulators, having held oversight responsibilities across many of the UK’s leading regulatory bodies

Before joining the civil service, Sarah was a Partner at McKinsey, where she led the firm’s Strategy and Corporate Finance practice in the UK and Ireland. She is currently a Board member at the University of Manchester and has previously served on the Board of UK Government Investments.

ASA Report on 2025 Independent Review outcomes

Eligible Independent Review requests were exceptionally low in numbers in 2025.

We published 298 Rulings in 2025 (280 in 2024). A further 58 cases were closed as NAICD* (114 in 2024). The following table puts Independent Review requests accepted by the IR into the context of all the cases eligible for review.

All review cases received by Independent Reviewer in 2025

Eligible Independent Review requests received by Independent Reviewer (10 in 2024) Of which:

Seven were of Rulings, 2.3% of all Rulings in 2025; (1.8% in 2024)

Two were of NAICD cases, 43.4% of all NAICD cases in 2025; (4.4% in 2024)

Number of Formal Investigation review requests the Independent Reviewer recommended for corrective action

Two Rulings, (0.7% of all Rulings) in 2024; (0.7% in 2024)

Number of NAICD case review requests the Independent Reviewer recommended for corrective action

Zero NAICDs (0% of all NAICD cases) in 2024; (0% in 2024)

We commit to deliver against a quality target of there being no more than 3% of our Rulings that are considered by the Independent Reviewer to require any form of corrective action. We met this target with just 0.7% of Rulings referred for a form of corrective action.

Two cases recommended for corrective action out of nine reviewed eligible requests means that the Independent Reviewer recommended some form of corrective action in 22% of all review requests.

* NAICD = No additional investigation after Council Decision