“We will put people first and prioritise protecting vulnerable people.”

The first strand of our latest strategy,  AI-Assisted Collective Ad Regulation, sets a clear and powerful ambition. We’re committed to increasing our efforts to protect vulnerable people and to support those who need our help the most.

A vulnerable person is someone who is particularly susceptible to harm or exploitation due to their personal circumstances. Various factors play a role in understanding someone’s potential vulnerability. In the context of advertising, if someone is vulnerable, an individual’s ability to understand the persuasive intent of advertisements can be affected. It can lead to them being more easily influenced and may limit their ability to make informed decisions.

Vulnerability can be situational, such as someone experiencing a temporary crisis, or inherent, such as a person with a long-term disability. Some common factors that can increase vulnerability include:

• Age (children, young people, and older adults)  

• Health challenges including disabilities 

• Mental Health challenges 

• Psychological states that include grief and stress 

• Addictions including gambling and alcohol 

• Financial position 

• Having English as a second language  

This list is not exhaustive and ultimately, any personal situation could lead to someone being more easily influenced by an ad. Nor is everyone within a certain category necessarily a vulnerable consumer. But it is why it’s important that all ads are legal, decent, honest and truthful.

Whilst our strategy looks to keep protecting vulnerable consumers at the forefront of our minds, doing so has always formed the heart of our work. Our rules frame our day-to-day activities, and we have Code Rules that specifically focus on protecting particular vulnerable groups such as children.  

Already this year, we have used our Active Ad monitoring system to drive our proactive work, published rulings and undertaken research to enforce our Code rules:  

• We’ve published a report into the depiction of older people in advertising.  

• We’ve published 6 rulings against ads for liquid BBLs (Brazilian Butt Lifts) after they irresponsibly pressured people into booking a cosmetic procedure and exploited women’s insecurities around body image. 

• We’ve conducted research into understanding how young people connect with media, sport and celebrities which will help inform what holds strong appeal to those under-18s. This is especially important when considering ads for age-restricted products, such as gambling and alcohol.  

• Our 2024 Annual Report also outlined other areas where we are using technology to help target our work on protecting vulnerable consumers.

But there is always more to do, and more to learn. What constitutes being vulnerable is often fluid and takes many forms; as such we have set-up an internal project team with the aim of helping us better understand the experiences of vulnerable people, and how this should be considered within our regulation.

The team will be looking to invite other regulators and representative groups of vulnerable consumers to share with us through discussion and presentations how they work to support and protect vulnerable consumers. We’ll also discuss how advertising may impact particular vulnerabilities.

This further insight into the experiences of vulnerable people and the work of other regulators will help guide the work that we do to protect vulnerable audiences. We also hope it will offer reflections about how we communicate with members of the public and advertisers, both in person and via our website. And whilst we fully recognise advertisers’ legitimate right to advertise, this project will ensure that as an organisation, we’re keeping our strategic goal of prioritising protecting vulnerable people as a primary focus.

If you fall within one of the above-mentioned groups or consider yourself vulnerable due to another reason, we’d welcome you letting us know when you contact us. We want to communicate with you in the most supportive and appropriate way. If you represent a group of vulnerable people and would like to discuss your experiences or concerns within the context of advertising, we’d welcome your input so please do get in touch through our telephone number or online enquiries form.

Most of us will experience being a vulnerable person at some point in their lifetime. The ASA and CAP are here to ensure that when that time occurs, the advertising you see, hear and engage with is responsible.

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More on

• Children and the vulnerable

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