Background
This investigation forms part of a wider piece of work related to online ads in the rail industry concerning "lowest" or "cheapest" price claims. See related rulings published on 24th December 2025.
Ad description
The ad must not appear again in the form complained about. We told Abellio Greater Anglia Ltd t/a Greater Anglia to ensure that they did not mislead consumers by claiming they could offer the lowest price available if that was not the case.Issue
The complainant challenged whether the claim “Book direct for lowest prices” was misleading.
Response
Abellio Greater Anglia Ltd t/a Greater Anglia said the purpose of the claim was to inform consumers that they offered the lowest ticket on any given day, including where advance tickets were available. They explained that ticket prices were the same across all retailers, in accordance with the National Rail Ticketing and Settlement Agreement (TSA). However, they said their booking system automatically highlighted the best fare available for a consumer’s journey, and that the overall cost could be cheaper than other retailers because Greater Anglia did not charge any booking fees.Greater Anglia said that after reviewing the complaint they acknowledged that their messaging was confusing. They said that although split ticketing options available through third-party retailers meant it was possible to slightly reduce fares on some journeys (by splitting a journey into multiple tickets), those same fares could be achieved on the Greater Anglia website if the customer chose to purchase their tickets separately. They said they understood, however, that not all consumers would be aware that they could do that.
Greater Anglia said they had amended their claim to state “No Booking Fees”.
Assessment
Upheld
The ASA considered that consumers would understand the claim “Book direct for lowest prices” to mean that by using Greater Anglia’s journey planner, they would be able to purchase Greater Anglia tickets at the lowest available price for their chosen journey. We considered that the claim was a “lowest price” (or “best price”) claim. As such, it needed to be backed up by suitable evidence to show that Greater Anglia would always beat, and not merely match, competitors’ prices.
We considered that rail ticketing was complex, and most consumers were unlikely to have knowledge of the rules which governed how ticket prices were set. Overall, consumers were likely to understand that Greater Anglia was able to offer competitively priced tickets, which they did by monitoring their fares against their competitors, including third-party retailers. We therefore expected Greater Anglia to hold evidence to substantiate the claim “Book direct for lowest prices”.
We understood that the framework in which train operating companies could set rail fares was set out by the TSA, and that operators such as Greater Anglia were not permitted to create or sell their own fares outside of that framework. We acknowledged that Greater Anglia did not charge a booking fee. However, we understood some third-party retailers also did not charge a booking fee, which meant Greater Anglia could not beat competitors’ prices. In addition, Greater Anglia accepted it might have been possible for consumers to find cheaper tickets through third-party split-ticketing providers for a complete journey. We understood that split-ticketing services operated by taking a complete journey input by the consumer and breaking it into two or more single tickets, often, but not always, involving a change of seat, train, or train operator. Notwithstanding any booking fees, the split journey suggested was sometimes found to be cheaper than booking a direct journey through the rail company. Due to those reason, we considered that Greater Anglia could not guarantee their tickets were always the cheapest.
We acknowledged Greater Anglia’s view that cheaper fares found through split-ticketing providers could also be achieved on the Greater Anglia website if the consumers chose to purchase their tickets separately. However, consumers would only be able to do that if they were aware that it may be possible to find a cheaper fare for an entire journey by splitting their travel over several different tickets. Greater Anglia acknowledged that not all consumers would be aware of the option to split fares in such a way. As such, we considered that the claim “Book direct for lowest prices” discouraged consumers from searching elsewhere for cheaper tickets. They also provided no evidence that, through purchasing tickets separately on the Greater Anglia website, they would always beat competitors’ prices.
We welcomed the action Greater Anglia had taken to amend their website. However, because we had seen no evidence to demonstrate that consumers could obtain the lowest available price by booking directly with Greater Anglia, we concluded that the ad was misleading.
The ad breached CAP Code (Edition 12) rules 3.1, 3.3 (Misleading advertising) and 3.7 (Substantiation).
Action
The ad must not appear again in the form complained about. We told Abellio Greater Anglia Ltd t/a Greater Anglia to ensure that they did not mislead consumers by claiming they could offer the lowest price available if that was not the case.
