Prices: General

Note: This advice is given by the CAP Executive about non-broadcast advertising. It does not constitute legal advice. It does not bind CAP, CAP advisory panels or the Advertising Standards Authority.

Also known as: pricing overview, pricing, cost, price comparisons, pricing in ads, price transparency

Rules 3.17 - 3.22 relate to price statements (which includes statements about the way the price will be calculated, as well as definite prices). Marketers should also review the guidance on price transparency from the Competitions and Markets Authority (CMA).

Ensure prices match the product shown

Include non-optional taxes, duties, fees and charges

Clearly state any commitment the consumer must make to obtain the price

Do not use “from” and “up to” to exaggerate the availability or potential savings

Price comparisons

Be aware of sector guidance

Ensure prices match the product shown

The ASA regularly upholds complaints about ads which feature products costing more than the stated price. Price statements must relate to the product featured in the ad and should not mislead by omission, undue emphasis or distortion (rule 3.17). The pricing claim in an ad for a perfume was deemed to be misleading because the pricing claim ("ONLY £4.95") related to a 5ml sample, rather than the 100ml bottle depicted (The Essence Vault Ltd, 15 January 2025) See also I Saw it First Ltd, 10 March 2021.

Similarly, marketers should not feature a picture of a top-of-the-range or enhanced product and quote in the headline a price for a lower specification model. In 2014, the ASA upheld a complaint that a car ad was misleading because the models featured were shown with metallic paint and alloy wheels, which were not included in the price shown (BMW UK Ltd, 5 March 2014.

If the product itself is a mystery (e.g. a box of random items from a product line), then any claims about its monetary value, including any discounts, must be accurate. In 2025, the ASA considered price claims made about a mystery box. The ad stated that the contents of the box was originally worth £89.99, but was being sold at a discount of 83%, at £14.99. The product the complainant received was worth less than £89.99, and the advertiser was unable to provide evidence that showed that the usual selling price of items in the mystery box was £89.99. Therefore, the ASA ruled that both the claim about the original price and the discount were misleading (Groupon International Ltd and Jaoyeh Trading Ltd, 30 April 2025).

Include non-optional taxes, duties, fees and charges

Quoted prices must include non-optional taxes, duties, fees and charges that apply to all or most buyers (rule 3.18). This includes, but is not limited to, transaction fees, locally-payable taxes (e.g. if tourists are required to pay a tax at a hotel abroad), and delivery charges.

For example, in 2019, the ASA ruled against an ad for a rental car company, because the quoted price did not include the non-optional car company hire fee (Rentalcars.com, 13 March 2019).

If it is not possible to calculate the charge in advance, for example because it depends on the consumer’s circumstances, the ad must make clear the charge is excluded from the advertised price and state how it will be calculated (rule 3.19). Whilst yet to be confirmed by the ASA by way of formal ruling, it is our understanding that, following the introduction of the Unfair Commercial Practices (UCP) provisions in the Digital Markets, Competition and Consumers Act 2024 (DMCCA), the information required under rule 3.19 needs to be set out with as much prominence as the advertised price. In the absence of any ASA precedent, marketers are advised to seek legal advice on this point.

If a price is included in an ad, any optional delivery, freight or postal charges which are not already included in the total price of the product must also be stated, unless they cannot be reasonably calculated in advance, in which case it must be made clear that such charges will be payable (rule 3.20, also see rule 3.4 for more information). The CMA guidance on price transparency states that if there is no free delivery/collection option for an online purchase, the quoted price should include the cost of the cheapest delivery option until the consumer chooses a different option.

In 2018, the ASA ruled that the price of a pair of shoes, which did not include the fixed delivery fee of £1.99, was misleading (Groupon Goods Global GmbH t/a Groupon, 30 May 2018). See also GET ME IN! Ltd, 7 March 2018.

For detailed guidance on these rules please see:

Compulsory costs and charges: General

Compulsory costs and charges: VAT

Compulsory costs and charges: Delivery charges

Compulsory costs and charges: Credit and debit card fees

Postage and packing

Clearly state any commitment the consumer must make to obtain the price

For minimum or fixed-term contracts, the quoted price must make clear the total price that the consumer will pay over that time. The CMA guidance on price transparency states that such a price can be presented as either:

The cumulative price that the consumer will have to pay over the entire minimum length of the contract, inclusive of all mandatory charges in that period; or
The total price that the consumer pays for each period of the contract, alongside a prominent statement of the number of periods the consumer is committed to pay that price for (e.g. "£30 per month for 12 months"). If there are any additional mandatory charges at the start of the contract (e.g. a one-off set-up fee), the advertised pricing must set out a total monthly price for the first month that includes those fees as well as a statement of how much the subsequent monthly payments will be (e.g. "£30 per month for 12 months, plus a £10 joining fee" or "12 month membership: £40 for the first month, then £30 per month for the next 11 months).

For example, the ASA ruled that the claim, "Pay monthly £7.99" for a subscription, but did not make clear upfront that there was a minimum commitment of 12 months, was misleading, because it did not make clear that consumers were comitted to paying £95.88 minimum (Team RH Fitness Ltd, 27 August 2025).

Prior to the introduction of the UCP provisions, the ASA ruled that the way in which a set-up fee, which only applied to certain customers, was not presented clearly or sufficiently prominently to help viewers understand the full cost that would be applicable to them (Sky UK Ltd, 12 August 2020). Even though this ruling predates the UCP provisions, the ASA could still consider that a similarly unclear pricing presentation may breach the CAP Code.

If the price of one product depends on another, marketing communications must make clear the extent of the commitment the consumer must make to obtain the advertised price (rule 3.21).

For example, a promoter offering a tie for £1 when customers buy a shirt for £20 cannot have an unqualified claim of “buy a tie for £1”. Such a promotion would need to be clarified immediately and prominently to explain customers’ financial obligation; for example, the promoter could claim “Shirt and Tie offer: £21”.

Do not use “from” and “up to” to exaggerate the availability or potential savings

Rule 3.22 states that price claims such as "up to" and "from" must not exaggerate the availability or amount of benefits likely to be obtained by the consumer.

When assessing “up to” and “from” saving claims the ASA are likely to have regard to the CTSI Guidance For Traders on Pricing Practices. This guidance states that, when using “from” or “up to” to advertise a saving, marketers must ensure that a significant proportion of sale items are discounted at the maximum saving, and that these claims represent the true overall picture of the price promotion.

What is considered a “significant proportion” may depend on individual factors in each case and the ASA will consider this on a case-by-case basis. An ad for a January sale which stated “up to 70% off plus a further 10% off” was upheld by the ASA because the number of sale items available at the maximum discount was 8.63%, which was not considered a significant proportion (Better Bathrooms UK Ltd, 4 October 2017). Similarly, an ad for “4 nights from” both £55 and £59 was deemed to be misleading, as only one break was available to book at the advertised price points. The ASA deemed this to be a small proportion of available breaks (Haven Leisure Ltd, 19 March 2025). See also Kiddies Kingdom Ltd, 13 October 2021.

Even where a significant proportion of items are available at the maximum saving, marketer should ensure that they include any relevant information or restrictions. For example, while a hotel chain was able to provide evidence that over 71% of available rooms could be booked at the "from" price of £25 in one location, and over 88% at the "from" price of £21 in another, these prices were only available for one night. In the absence of any information in the ads to indicate the date on which the advertised prices were available, the ASA concluded that the ads were misleading (Travelodge Hotels Ltd, 19 November 2025). By comparison, a hotel chain was able to demonstrate that 23% of their inventory was available at or (marginally) below the advertised "from" price of £33, spread evenly throughout the six months following the date of the ad. The ASA concluded that this use of a "from" price did not exaggerate the availability of potential savings (Accor (UK) Ltd, 19 November 2025).

When assessing whether an “up to” or “from” claim represents the true overall picture of a sale, the ASA is likely to expect the sale items with the maximum saving to be distributed across different price ranges. Even if a significant proportion of sales items have the maximum saving, if these sale items are disproportionately in the lower price ranges, an “up to” or “from” claim is still likely to mislead (Better Bathrooms UK Ltd, 4 October 2017).

If using both “from £XXX” and “up to XX% off” claims in the same ad, advertisers must be careful not to imply, by way of the ad’s presentation, that the claims are linked if this is not the case. For example, in a 2025 ruling, the ASA decided that the differences in font and layout of the “up to 46% off” and “from £135” claims were not significant enough to dispel the assumption that they related to each other. The ad (for a hotel room) was deemed to be misleading on this basis, and also because the value of additional benefits had been added to the usual selling price of the hotel room, which inflated the percentage discount figure (Secret Escapes Ltd, 19 February 2025).

In the absence of evidence to prove the savings claims within an ad, the ASA is likely to determine that the ad is misleading (Hilton Worldwide Ltd, 19 November 2025). See also Booking.com BV, 19 November 2025.

For further guidance on this point and others, such as reference pricing, see ‘Promotional savings claims’.

Price comparisons

Rule 3.38 states that marketing communications that include a price comparison must not mislead by failing to make the basis of the comparison clear.

For example, whilst marketers may legitimately make price comparisons between branded and non-branded products, the basis of the comparison must be clear. See Aldi Ltd, 29 June 2016.

The following guidance contains further information in respect of price comparisons:

Lowest price claims and promises

Comparisons: General

Comparisons: Baskets of goods

Price comparisons must not mislead by falsely claiming a price advantage. Comparisons with a recommended retail price (RRPs) are likely to mislead if the RRP differs significantly from the price at which the product or service is generally sold (rule 3.39).

The ASA considered the claim “HALF PRICE!...RRP £29.99 NOW ONLY £14.99” to be misleading, as the product was only ever sold for £14.99, and not at the RRP (Vytaliving Ltd, 27 March 2024).

For further information see ‘Prices: recommended retail prices (RRPs)’ and ‘Promotional savings claims’.