Without wishing to channel our inner Scrooge, it’s important for us to remind you that the Advertising Codes apply all year around. Christmas is no exception. Below are four ways to ensure its ‘Christmas as usual’ for your 2025 festive campaigns.
All the Trimmings
If your marketing menu includes ads for festive foods, your offers can be as generous as Scrooge on Christmas Day, but don’t be a miser with the terms and conditions.
Ads promoting cheaper foods should make sure the basis of that comparison is fair and supported by accurate evidence. You can avoid misleading consumers by ensuring you’re clear about the nature of your offering, whether that’s the value of a frozen turkey, or making sure your vegan-friendly alternative is just that.
Fizzy Swigs
A responsible alcohol ad is not just for Christmas but avoid the temptation to go overboard when tantalising with a tipple. Promoting a “barrow of booze” could lead people to drink to excess and be considered irresponsible.
Alcohol should not be portrayed as a key component in the success of a social event, but that’s not to say your ads should be sober, provided you take care with the presentation.
Be more Scrooge: don’t encourage irresponsible spending
You must not encourage irresponsible Christmas spending using credit. This includes via Buy Now, Pay Later schemes.
The ASA published two rulings upholding complaints against ads for ‘Christmas loans’. One offered to ‘Take the stress out of the festive season…’ and said customers could ‘Cherish every moment of the holidays without fretting over your budget’.
According to the ASA, the ad suggested the loan could make Christmas stress-free. It reinforced the impression consumers would, by taking the loan, avoid financial worry, and be able to spend more. The ASA decided the claims and imagery made light of the decision to take on debt and encouraged overspending. The ad was, therefore, considered socially irresponsible, contrary to Rule 1.3. The same conclusion was reached in respect of a second ad.
Tiny (and not so tiny) Tots
There are plenty of rules in the Codes that are intended to protect children from being misled, harmed or indeed portrayed in a sexual manner.
Make sure ads are not seen to encourage dangerous or unsafe behaviour. The ASA has, for example, upheld a complaint about a catalogue advert for a “Fire Station” play tent that showed an image of children putting out a real fire.
If you’re advertising restricted products (i.e. gambling, alcohol etc), be cautious when using Christmas as a theme.
Ads for gambling products must not appeal strongly to under 18s (Rule 16.3.12). As explained here, depictions of Christmas and its traditions are likely to be of strong appeal.
That said, it’s ultimately how Christmas is depicted which will determine if an ad is likely to hold strong appeal. For example, when ruling on an ad featuring a choir singing carols, the ASA decided this depiction of Christmas was unlikely to appeal strong to children.
Similar rules prohibit ads for other restricted products, like alcohol, from appealing particularly to children (Rule 18.15). For example, in this ruling (Bestway Retail Ltd t/a Bargain Booze, 19 March 2025) the ASA acknowledged that the fictitious character of Father Christmas has appeal to people of all ages. However, notwithstanding that, they considered Christmas, and the traditions surrounding it, were likely to appeal to children. They noted, for instance, that the ad contained magical elements including a “naughty or nice” barometer, which they considered children might have an affinity with, and found the ad in breach on that basis.
Check out our website for more Christmas themed guidance and if you need advice on your non-broadcast ads our Copy Advice team are here to oblige.
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