Mind the (price) gap: train ticket price claims that stay on track

Train ticket pricing can be a maze. When ads promise “cheapest”, “lowest” or “best price”, consumers may hear: “don’t bother checking anywhere else.” The ASA has upheld complaints about that kind of messaging for ScotRail, Greater Anglia and MyTrainTicket.

Cheapest tickets?

Claims and headlines like “GET CHEAPEST TICKETS” or “Book direct for lowest prices” were understood as lowest or best price claims, suggesting that consumers could get the lowest available price for their journey and wouldn’t need to look elsewhere.

Next stop: substantiation

If you’re going to say ‘cheapest’, ‘lowest’ or ‘best price’ you need evidence to support it (the substantiation principle set out in CAP Code rule 3.7).

The ASA’s ruling on Trainline is a useful “don’t do this” example: ads saying “You won’t find cheaper… anywhere else” were treated as absolute lowest-price claims, and the ASA upheld because Trainline couldn’t substantiate that impression.

Remember, you shouldn’t confuse “lowest price guarantee” and “lowest price guaranteed”. The latter means there’s no lower price than yours because you’ve checked, so customers shouldn’t bother looking elsewhere. The former is a promise you’re making to consumers – there might be cheaper prices out there – but if there are, you’ll match it/refund the difference etc.

Quick refresher: Lowest price claims and promises.

“No booking fees”?

If the real benefit is no booking fee, say that. Don’t hitch it to “lowest prices” unless you can support the broader impression.

Greater Anglia acknowledged that consumers might be able to find cheaper fares than they offered and amended their advertising to focus on “No Booking Fees”.

Split tickets, split claims?

Split-ticketing can mean a third party offers a cheaper fare by splitting the journey into multiple tickets. If your tool doesn’t reliably deliver the overall cheapest option (including split itineraries), don’t imply it does.

Price promise? Not a free ride

A “price promise” doesn’t automatically make “lowest price” headlines safe.

In the ScotRail ruling, the ASA noted the promise didn’t apply universally and didn’t guarantee beating all competitors in all circumstances. And in the Avanti West Coast ruling, “unbeatable”/ “no need for shopping around” messaging linked to a price promise was found misleading in context (including around split-ticketing).

“From £X”?

Lead-in fares are a classic platform-edge risk: consumers need a realistic chance of getting the “from” price, and key limitations (like travel dates) shouldn’t be tucked away.

In the Eurostar ruling, social media posts that claimed “from £39 each way” were found to be misleading because Eurostar couldn’t show a significant proportion were available at that price and the specific date limitations weren’t made clear in the ads.

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