Background
This Ruling forms part of a wider piece of work on misleadingness in ads for accident claims management companies. The ads were identified for investigation following intelligence gathered by our Active Ad Monitoring system, which uses AI to proactively search for online ads that might break the rules. See also related rulings published on 7 January and 29 April 2026.
Summary of Council decision:
Two issues were investigated, both of which were Upheld.
Ad description
Two paid-for Google search listings and a web landing page for Motor Claims Line, an accident management company, seen on 11 July 2025:
a. The first paid-for Google search result was headlined “Free Accident Claim Assessment – Don’t Contact Your Insurer Yet”. Text stated, “Get back on the road with minimal hassle & money saved, without affecting your insurance. Get a like-for-like replacement vehicle within 24 hours. No excess payments needed. Save Money.” The ad stated, “Sponsored” in the top left-hand corner and displayed a web address: “www.motorclaimsline.co.uk/”.
b. Another paid-for Google search result was headlined “Motor Claims Line Guaranteed 100% Free Service”. Text stated, “Had a road accident? Making an insurance claim? Use our completely free service today. Accident claims management service – roadside recovery, replacement vehicle & repairs. UK Customer Support. Back On The Road in 24h. Independent Service. Available By Phone.” A box with a telephone icon stated “Call us”. The ad stated, “Sponsored” in the top left-hand corner and displayed a web address: “www.motorclaimsline.co.uk/”.
c. The landing page for ads (a) and (b), www.motorclaimsline.co.uk, was headlined “Keep your insurance policy squeaky clean”. Text stated, “A totally hassle-free service that keeps your own policy completely clean in the event of a road traffic accident Like-4-like replacement vehicle No excess to pay- average saving £348 We act for you, Not the insurer We won’t ask you to pay a penny towards your excess”. Further text stated, “After an accident call us before you call your insurer. We’re changing our clients [sic] minds. Its [sic] completely hassle-free All costs recovered from the other side’s insurer, so it doesn’t cost you a penny. Save £££ Nearly 100% of our customers saved money by using us to manage their claim”.
The landing page featured a further section entitled “Our core services following a road accident” which included the claims “Roadside recovery Your vehicle recovered from the roadside free of charge Replacement vehicle Like-4-like replacement vehicle within 24 hours Claim management We will manage the whole process from start to finish”. Another section, which set out the process timeline, was entitled “Our process is super simple! Call us after your accident before you contact your own insurer”.
Issue
The ASA challenged whether the ads:
- misled in relation to the nature of the service; and
- misleadingly implied that there would be no cost to the consumer, and that consumers could therefore make savings by using their service.
Response
1. & 2. CC Response NW Ltd t/a Motor Claims Line (CC Response) said the claim “100% Free Service” in ad (b) had been generated by AI and they had since removed it. They had taken action to ensure that similar phrases would not be used in future campaigns, strengthened their internal approval process and said any future ad copy would be approved by one of their directors.
CC Response confirmed that they dealt only with no-fault claims. If, during the initial consultation, they determined that the accident was the customer’s fault they would advise that the customer would need to contact their insurer. If the accident was not the customer’s fault, they would explain the benefits of their service and why the customer might choose to use them instead of their own or the third-party’s insurer.
CC Response explained that their claim assessment process was free with no obligation. Customers would call to discuss the circumstances of their accident and the services offered would be explained to them during the call. They informed customers that they could notify their own insurers for information purposes only. They believed the statement “don’t call your insurer yet” allowed customers to explore all options and make an informed decision. They added that they did not at any point suggest to customers to act out of line with the requirements of their insurance policy.
CC Response said clients were informed of the costs associated with their service during the initial phone call. They said at no other point did they give the impression that the service was entirely without cost. Typically, charges were covered by the third-party at-fault driver’s insurer, meaning that it was very unlikely that the customer would ever be required to pay directly. They said before any service was provided, such as the credit hire agreement for a replacement car, the potential costs were explained in detail and a written agreement was provided for review and signature. They believed by the time they took up the service, customers would therefore understand the terms and that the service was not completely free.
CC Response said the claim “Nearly 100% of our customers saved money” was based on the success rate of the claims they processed. The specific figure, which they said they would use in future advertising, with an explanation of its basis, was 95.36%. That related to those customers who had used their service from 2021 to 2025 and who had remained with them until the conclusion of the claim. Their success rate was due largely to their vetting process, which determined that the claim was no-fault before they provided services. They added that only a very low proportion of the claims they took on were closed due to the accident turning out to be the customer’s fault; in those circumstances they would not seek recovery of any credit hire charges incurred.
CC Response said the claim “average saving £348” was intended to illustrate the typical UK voluntary excess avoided in non-fault claims. They said they would update the figure to state a range of between £100 and £550 with an explanation of the basis of the estimate. They added that they would amend their website to avoid presenting a definitive savings claim.
Assessment
1.Upheld
Ads (a) and (b) included the claims “Free Accident Claim Assessment – Don’t Contact Your Insurer Yet”, “Get back on the road”, “Motor Claims Line” and “Accident claims management service”. The ASA considered that consumers were likely to understand from those claims that the advertiser was an accident claims management company who they could contact for assistance in the event of a motor accident insurance claim.
We considered that consumers involved in an accident, were generally likely to be in a hurry to get assistance and might search online for such help shortly, if not immediately, after the accident, when they were likely to be particularly vulnerable. We further considered that claims such as “Get back on the road with minimal hassle […]” in ad (a) and “Had a road accident? Making an insurance claim? Use our completely free service today” in ad (b) suggested that anyone involved in an accident would be able to use CC Response’s services. Further, ad (a) stated, “Don’t Contact Your Insurer Yet” and ad (c) stated, “After an accident call us before you call your insurer” and “Call us after your accident before you contact your own insurer”. We noted, however, CC Response handled only no-fault accident claims. That was not referenced in ads (a) or (b), or on the landing page, ad (c), which also stated, “After an accident call us before you call your insurer. We’re changing our clients [sic] minds. Its [sic] completely hassle-free All costs recovered from the other side’s insurer, so it doesn’t cost you a penny”. The ads therefore did not make the non-fault accident limitation clear and we considered they instead implied that CC Response dealt with all accident claims.
We further understood that consumers who did not notify their own insurer of an accident, regardless of whether a claim was made, risked affecting their cover. However, none of the ads made clear the risks to consumers of failing to notify their insurer after an accident.
We welcomed CC Response’s willingness to make changes to their advertising and acknowledged that the search result ads were limited by space. However, we considered that information about CC Response handling only non-fault claims was material to a consumer’s decision to engage with the service, was easily and succinctly conveyed and should have appeared in the Google search ads. The risk of not notifying their insurer, was also material information, which should have appeared clearly, at least on the landing page ad (c).
Because the ads did not make that information referred to above clear to consumers, we concluded that they misled in relation to the nature of the service being offered.
On that point, ads (a), (b) and (c) breached CAP Code (Edition 12) rules 3.1 and 3.3 (Misleading advertising and 3.9 (Qualification).
2. Upheld
Ad (a) stated “Free Accident Claim Assessment” and “No excess payments” and ad (b) stated “Guaranteed 100% Free Service”. The landing page, ad (c), stated “All costs recovered from the other side’s insurer, so it doesn’t cost you a penny”. We considered that consumers would understand from the claims that they would not be liable for any cost in connection with making a claim.
We noted CC Response stated that the service they provided was not completely free. We understood that consumers became liable for costs when they entered into a credit agreement, for example when a replacement car was arranged. While typically costs would be met by the third party driver’s insurer, that could not be guaranteed. For example, the fault for the accident might be disputed and need to be established, not necessarily successfully, or the level of car hire charges might be disputed. In cases where the third-party’s insurer would not pay, we understood that consumers could be responsible for the costs already incurred, such as vehicle recovery, repairs, storage or a replacement vehicle.
Ad (a) additionally stated, “money saved” and “No excess payments needed. Save Money”. Ad (c) included the claims “Average saving £348” and “Save £££ Nearly 100% of our customers saved money by using us to manage their claim” and “We won’t ask you to pay a penny towards your excess”. We considered that consumers were likely to understand that they would nearly always save money by using the advertised service instead of making a claim via their insurance provider.
We noted the savings claims were intended to relate only to no-fault claims that had been successfully processed and where the customer had remained with CC Response until the claim conclusion. We also noted the average saving of £348 was based on the typical voluntary excess that a consumer might pay when claiming through their insurance provider for a no-fault claim. However, the basis of the savings claim was not made clear in the ads.
In addition, we understood the saving did not take into account the costs a consumer might incur as a result of claiming through an accident management company instead of their insurance provider.
We welcomed CC Response’s willingness to amend their savings claims. However, because of the implication that there would be no cost to the consumer when that was not always the case, and because the savings claims suggested greater potential benefits than were available, we concluded that they were misleading.
On that point, ads (a), (b) and (c) breached CAP Code (Edition 12) rules 3.1 and 3.3 (Misleading advertising), 3.9 (Qualification). 3.17 (Prices) and 3.38 (Price comparisons).
Action
Ads (a), (b) and (c) must not appear again in the form complained of. We told CC Response NW Ltd t/a Motor Claims Line to ensure that their future ads made clear to consumers the nature of their service, including in relation to non-fault accidents, that they did not imply there was no cost to the consumer if that was not the case and did not mislead in relation to potential savings.
