Superimposed text: a call for evidence

We are calling for evidence on the use of superimposed text (“supers”) in TV ads. Supers are the terms and conditions – referred to as “small print” – that viewers usually see at the bottom of a TV ad. Supers enable the advertiser to expand on, and qualify, the main messages of an ad.

Supers should not, however, contradict the main message of an ad or serve as a means of hiding important information. We see from ASA complaints that, sometimes, consumers find it difficult to read them in the context of the wider ad.

We want to ensure that we have an up-to-date picture of viewer engagement with, and understanding of, supers. This will inform our investigation of complaints we receive about them.

We would welcome evidence on:

  • How consumers use supers in broadcast ads – for example, any research on whether viewers notice supers or seek them out and the reasons for this.
  • The extent to which supers are legible to viewers and what presentational factors are key in determining this – for example, any research relating to the impact of the font of the text, the spacing of the letters, how long the text is on screen for or the length of the text. Research on the legibility of text in other contexts may also be of relevance.
  • The extent to which consumers understand the content of supers – this may encompass research relating to consumer understanding of the types of qualifiers and clarifications that may appear in ads for financial services, utilities, insurance or gambling ads.
  • Whether and how the use, legibility or comprehension of supers differs by demographics or visual acuity.

We recognise that evidence can take many forms. Stakeholders may choose to submit existing evidence, secondary analysis or bespoke research. Quantitative and qualitative would both be useful to us.

Responses will be viewed alongside consumer research commissioned by the ASA, which is currently underway. The evidence and research findings will help BCAP improve the information available to advertisers to ensure they are getting it right, and the ASA in making its decisions and applying the advertising rules.

Please submit responses or questions by emailing [email protected]. Submissions should be sent to us by 31 July.

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