Easter is coming up - a time associated with many different things including egg hunts, hot cross buns, lots of chocolate…and also taking advantage of seasonal promotional offers. To avoid getting egg on your face, here are three key considerations for Easter promotions.
Take care when egg-stimating demand
Before advertising a promotion, you should always ensure you have made a reasonable estimate of demand and that you can demonstrate that you’ve done so. This estimate should always take into account any factors that could have an impact on demand, for example the popularity of different products at different times of year.
The ASA previously concluded that ASDA had made a reasonable estimate of demand for an Easter promotion on salmon because, along with other factors, they had acknowledged the different time of year when estimating demand based on a previous promotion which ran at Christmas.
If the availability of your promotional items is not enough to meet your estimated demand, or if customers need to make a purchase to qualify for the promotional item, you must make any limitations on availability explicitly clear in the ad – “subject to availability” might not be enough.
Ovoid causing offence
Easter holds religious significance for many consumers, particularly those of the Christian faith. Advertisers should therefore take care when preparing their Easter promotions to ensure they don’t contain anything which could cause serious or widespread offence.
Indeed, an email by Boylesports Enterprise which featured a monetary bonus when consumers staked a minimum amount on a betting game was deemed to be offensive. The ad featured blood dripping down from a hand which was nailed to a length of wood and text which stated, “In memory of the dearly departed JC, we’re offering you a sacrilicious Bonus this Easter weekend!”.
The ASA considered the combination of the jokey language and imagery used caused serious offence, which was likely to be felt particularly strongly by those of the Christian faith at Easter, when the imagery would have particular resonance.
Don’t gamble when scrambling your targeting
As well as ensuring promotional offers do not mislead, advertisers should also remember that the rest of the Code will apply to ads.
In 2025, the ASA considered an ad for Play’n GO Malta Ltd (16 July 2025), when two complainants, who had seen the ads beside their own or their child’s email inbox, challenged whether the ads featured content likely to be of strong appeal to those aged under 18 years of age.
One ad featured a cartoon image of the Easter Bunny holding a basket of eggs, suggesting an Easter egg hunt, which was an activity enjoyed by children. The ASA considered that because of those elements, the image was likely to strongly appeal to under-18s. The ASA considered that the targeting measures used, which relied on self-declaration of age of users entering the Play’n GO website and retargeting based on that data, as well as prospecting targeting using browsing behaviours, were not sufficiently robust to ensure under-18s were entirely excluded from the audience, and the complaints were upheld.
Don’t crack under the pressure of compliance - you can get free and confidential advice on your non-broadcast ads by contacting the CAP Copy Advice team.
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