Background
This Ruling forms part of a wider piece of work on advertising for greener heating and insulation products. The ads were identified for investigation following intelligence gathering by our Active Ad Monitoring system, which uses AI to proactively survey ads in specific sectors. See also related rulings published on 6 August 2025.
On 7 April 2025, the Advertising Codes were updated to reflect the revocation and restatement of the Consumer Protection from Unfair Trading Regulations 2008 (CPRs – the legislation from which the majority of the CAP and BCAP rules on misleading advertising derived) by the Unfair Commercial Practices provisions in the Digital Markets, Competition and Consumers Act 2024 (DMCCA).
On that date, the wording of a number of the rules in the Advertising Codes was changed to reflect relevant changes introduced by the DMCCA on 6 April 2025. Given that the complaint that formed the subject of this ruling was received before 7 April 2025, the ASA considered the ad(s) and complaint under the wording of the rules that existed prior to 7 April 2025, and the Ruling (and references to rules within it) should therefore be read in line with this wording, available here – CAP Code and BCAP Code.
Ad description
A paid-for Meta ad for Aira, a residential home heating products supplier, seen on 5 March 2025 featured an image of a boiler and a heat pump. Text in the ad’s caption stated, "Ditch your gas boiler for an Aira heat pump today [...] £7,500 grant available".
Issue
The ASA challenged whether the ad was misleading because it omitted material information about the government funding available for installing heat pumps.
Response
Aira Home UK Ltd t/a Aira said the ad was only targeted at homeowners living in England and Scotland where £7,500 government grants were available to replace their gas boiler with a heat pump. They explained that a grant was available to homeowners in England and Wales under the Boiler Upgrade Scheme (BUS) and in Scotland under the Home Energy Scotland Grant and Loan Scheme (HESG&L).
They did not believe that a consumer would interpret the ad to mean the grants were given automatically and without conditions. Social media ads did not allow for extensive clarification and consumers would be confused by including phrasing such as “eligibility criteria apply” as it would lead them to believe that qualifying for a grant was overly difficult. They said, in practice, nearly all of their customers who replaced a gas boiler in their own home with a heat pump were eligible for a £7,500 grant.
The ad clicked through to a landing page on their website where consumers were invited to get a quote for a heat pump. As part of the consumer journey, if a consumer completed their details in the online form, they would then call the customer directly to determine their eligibility. Detailed information about the grants was available on their website and customers could navigate to those pages from the menu on the homepage.
On receipt of the complaint, they changed the ad’s landing page, adding a note to the bottom of that page titled “Grant Eligibility Criteria” which when clicked raised a pop-up box that detailed the eligibility criteria for the BUS and HESG&L grants.
Assessment
Upheld
The CAP Code stated marketing communications must not mislead the consumer by omitting material information. Guidance from the Competition and Markets Authority (CMA) advised that if marketers referred to government funding anywhere in their marketing, they should be clear that access to funding was subject to a consumer meeting the eligibility criteria. The ASA had regard to the guidance in assessing whether the ad had complied with the CAP Code.
We understood there were a number of eligibility criteria that consumers needed to satisfy in order to qualify for funding for a heat pump and those differed between the BUS and HESG&L. Under the BUS, they included that the applicant must be a homeowner of a non-new build house in England or Wales with a valid Energy Performance Certificate (EPC), replacing an existing fossil fuel heating system and only receiving funding from one source of public funds. Under the HESG&L, the applicant must own or jointly own a property in Scotland as either their only or principal private residence, the property must be registered with the Scottish Assessors Association as paying domestic council tax rates and the property must have a valid EPC.
The ad stated, “Ditch your gas boiler for an Aira heat pump today [...] £7,500 grant available". While the ad referred to a “£7,500 grant” (which would be understood as referring to government funding), it did not include information about eligibility criteria having to be satisfied in order to receive the grant. In the absence of that information, we considered the ad gave the impression that all consumers were eligible for £7,500 of government funding to have a heat pump installed.
The ad linked to a landing page, one click away, which referred to the available funding but it neither referred to nor included information about eligibility criteria. We acknowledged that there was a dedicated page on Aira’s website, accessible from the main menu, with information about heat pump funding and which contained links to learn more about the BUS and the HESG&L. However, consumers would only have been aware of that information if they visited the relevant page and read the full page of text, which was not necessary to obtain a quote to have a heat pump installed. We considered that the fact the funding was subject to meeting specific criteria was material information that was likely to affect consumers’ understanding of the ad’s overall message and was therefore required to be stated in the ad, so that consumers could proceed further into the consumer journey of obtaining a quote for a heat pump installation with Aira in an informed manner. We further considered the ad was not limited by time or space to such an extent that the information could not be provided.
We welcomed that Aira had amended the ad’s landing page to include information about the eligibility criteria for the two schemes. However, that information was at the bottom of the landing page and consumers would only be aware of it if they scrolled to the bottom and read the full page of text. Consumers did not need to do that in order to obtain a quote for a heat pump to be installed. The information about the eligibility criteria was, therefore, insufficiently prominent.
The ad gave the impression consumers would be automatically eligible to receive a government grant of £7,500 and it did not make clear the government funding for a heat pump was subject to eligibility.
We considered that was material information that should have been included. Because the ad omitted material information, we concluded it was likely to mislead.
The ad breached CAP Code (Edition 12) rules 3.1, 3.3 and 3.9 (Misleading advertising).
Action
The ad must not appear again in the form investigated. We told Aira Home UK Ltd t/a Aira to ensure ads that referred to the government grants for heat pumps included all material information, including that eligibility criteria applied.
