Ad description
A national press ad, seen in May 2025, for Hive featured an image of a building in a field with solar panels on its roof. The headline stated “Today’s sunshine. Tomorrow’s savings”. Text beneath stated “Shrink your electricity bills by up to 94% in your first year with solar – search solar with Hive” and “T&Cs apply. Savings based on year one”.
Issue
The ASA challenged whether the:
- claim “Shrink your electricity bills by up to 94% in your first year with solar” was misleading and could be substantiated; and
- ad omitted material information.
Response
1. Centrica Hive Ltd t/a Hive stated that the savings claim was presented as an “up to” figure, which indicated that a significant proportion of consumers were able to achieve that level of saving, rather than suggesting that all would. The 94% figure arose from comparing the potential savings a customer could achieve by installing a solar photovoltaic system with a battery, together with taking a British Gas (Centrica Hive and British Gas belong to the same corporate group) Smart Export Guarantee (SEG) tariff and Solar Saver energy offer, versus relying solely on grid electricity.
They explained the 94% saving had been derived from a model that estimated a customer’s electricity bill savings after installing a solar panel system. The model was based on assumptions around pre-and-post installation electricity usage and costs, property location, tariff types – the default tariff subject to the price cap which reflected what the majority of consumers were currently on, and system configuration.
Pre-installation electricity usage was based on calculations from the Office of Gas and Electricity Markets (Ofgem)’s 2023 Typical Domestic Consumption Values (TDCVs) for medium-usage households, which was based on median electricity consumption usage for properties across the UK. They explained that was the best way to estimate likely energy usage as the figures were based on a large dataset, which ensured accuracy and representativeness, and realistically reflected typical household consumption. They said, as a significant proportion of their customers needed to achieve the savings claim, it was appropriate to base the claim, in relation to pre-installation electricity usage, on a property with medium energy usage. The TDCV rates were designed by Ofgem for energy suppliers and price comparison websites to use when a consumer’s actual annual consumption was unknown. They said the savings claim was made in relation to electricity obtained through the national grid and was not a comparison against any of their competitor’s prices or their products. In terms of system configuration, they acknowledged that the number of solar panels shown in the ad was inconsistent with the number of panels assumed in the model.
They supplied an additional breakdown of data based on actual customer solar panel installations, which identified customers within the British Gas billing system who had solar and battery systems installed by Hive since the offer launched and had been receiving SEG payments from British Gas. The data compared electricity usage and rates over a 12-month period before installation when it was supplied from the grid to a 12-month period after the solar panels and battery system had been installed. The additional breakdown of data did not make assumptions about a customer’s property size, location, system size, or tariff, and if the customer was on a fixed tariff before or after installation, that was taken into account. Hive explained that due to their solar panel range having been live for just over a year, some customers’ electricity usage was calculated, basing it on their actual usage patterns post-installation, for the full 12-month period. They said that additional breakdown of data based on actual customer solar panel installations demonstrated 44% of customers achieved the 94% savings stated in the ad. Hive believed their approach was consistent with previous ASA decisions.
2. Hive stated that space restrictions in the ad meant full details explaining how the savings claim was calculated were not included. They highlighted the ad stated that “T&Cs apply” and included the call to action “Search Solar with Hive”. Individuals who searched that term were directed to the Hive Solar landing page which provided full details on how the savings claim was calculated.
Assessment
1. & 2. Upheld
The CAP Code stated that price claims such as “up to” must not exaggerate the availability or amount of benefits likely to be obtained by the consumer. The Competition and Markets Authority guidance ‘Marketing green heating and insulation products: Consumer law compliance advice for businesses’ (the CMA Guidance) stated that “up to” claims should reflect that at least a significant proportion of consumers would be likely to achieve the stated outcome. Where relevant, they should also reflect the range of factors that impact product performance. The ASA had regard to the guidance in assessing the ad against the CAP Code.
The ad featured an image of a property with eight solar panels on its roof and text stated, “Shrink your electricity bills by up to 94% in your first year with solar – search solar with Hive” and “T&Cs apply. Savings based on year one”. We considered consumers would understand the claim to mean that a significant proportion of consumers, who had at least eight panels installed by Hive, could save 94% on their electricity bills in the first year after installation. We acknowledged that Hive had based the savings claim on a comparison between electricity production via a heat pump and boiler, according to modelled criteria. However, the ad did not disclose that its savings claim was modelled, nor what the model’s criteria were. We assessed the ad, and the supporting substantiation that was provided, in relation to the ad’s specific overall presentation. We considered the consumers viewing the ad would likely be paying an existing energy bill and that context would impact their understanding of the ad's savings claim, which depended on receiving British Gas's Smart Export Guarantee tariff along with the Solar Saver offer (valid for the first 12 months after installation) applying. That meant the significant proportion of consumers who were able to save 94% were able to do so regardless of their energy supplier or the energy source they used prior to having solar panels installed.
We reviewed the summary of the modelled data and the additional breakdown of data based on actual customer solar panel installations that Hive provided.
The model covered two scenarios: the expected electricity cost if a consumer continued using electricity from the grid, and the expected electricity cost with a solar panel system installed, factoring in battery storage and export payments. The model was underpinned by assumptions around electricity rates and usage, property location, tariff types, and system configuration. Pre-installation energy usage was based on calculations from Ofgem’s 2023 TDCVs, for medium-usage households, estimated to be 2,700 kilowatt-hours (kWh) per year (7.39 kWh per day). The TDCVs were industry standard values for the annual electricity usage of a typical domestic user. Regarding the property location and system configuration, the modelled data was based on a property in London and assumed an installation of a 10-panel 4 kW solar photovoltaic system.
The model had assumed consumers were on the default price cap tariff, and we acknowledged the majority of consumers had their electricity provided at that rate. However, it had not demonstrated that a significant proportion of Hive’s actual customers, or those who switched from a tariff offered by another supplier would save 94% on their electricity bill, which, in the context of an ad that had not made clear its saving claim partly depended on that parameter, we considered was necessary. Similarly, we had not seen evidence that outlined that data based on median energy usage, or the parameters regarding property location and system configuration, was representative of Hive’s actual customers, which we considered necessary to substantiate the specific claim as it was made in the ad.
The savings claim was also based on consumers opting to have a storage battery included as part of their installation, which we understood was an optional extra. We acknowledged that a significant proportion of Hive’s customers opted to have a battery installed. However, as the ad did not clarify the savings claims was based on having a battery installed, we expected the evidence that substantiated the savings claim to demonstrate that a significant proportion of consumers who either did or did not have the battery installed were able to reduce their energy bills by 94%, and we had not been presented with evidence that demonstrated that.
The additional breakdown of data was based on actual customer solar panel installations, apart from when, due to the recency of the offer, Hive needed to calculate the energy usage for customers for whom they did not have 12 months of data, basing those calculations on the usage data they did have for that customer. We understood the data was not held at the time the ad was published, which was a requirement under the Code. It outlined the rates that 33 customers, the total number of customers for which Hive held the relevant data for, were being charged before and after having solar panels and joining Hive’s tariff. A comparison was then made between the change, as a percentage, of their two rates that were charged and the percentage of customer's achieving a certain level of the saving. Within that framing, 44% of customers were expected to achieve the 94% savings stated in the ad, with some expected to also incur higher bills after installation. We acknowledged the data accounted for customers, prior to install, who may have been on tariffs, provided by British Gas, that differed from the default price cap tariff. However, it had not accounted for customers who may have been on alternative tariffs from another supplier before switching to the British Gas Smart Export Guarantee tariff and Solar Saver energy offer provided by Hive. We considered that this was necessary for the ad’s savings claim, as the ad had not made clear that the claim had not accounted for customers who had been on alternative tariffs from another supplier and that was how we considered consumers would interpret the ad.
The ad stated, “T&Cs apply search solar with Hive’, which was an instruction for readers to continue their enquiry by conducting an internet search. The Hive website featured information to explain the 94% savings claim, including that it depended on 35% of a home’s electricity being supplied by solar panels and a battery. However, we considered that the basis of the savings claim, including that the savings figures were modelled and the assumptions underpinning it, was material information that was likely to affect a 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 installing solar panels 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.
As the savings claim was based on specific circumstances, which were undisclosed in the ad, and the evidence provided, assessed in regard to how the average consumer was likely to interpret the ad, did not demonstrate that a saving of “up to 94%” on their electricity bill could be achieved by a significant proportion of consumers in their first year after installing at least eight solar panels. We, therefore, concluded that the ad omitted material information and the savings claim as it was presented had not been adequately substantiated.
The ad breached CAP Code (Edition 12) rules 3.1, 3.3 (Misleading advertising), 3.7 (Substantiation), 3.9 (Qualification), 3.17, 3.22 (Prices) and 3.38 (Price comparisons).
Action
The ad must not appear again in the form investigated. We told Centrica Hive Ltd t/a Hive to ensure they held suitably robust evidence to demonstrate any “up to” savings claim could be achieved by a significant proportion of consumers. We also told them to ensure their ads included all material information, which, in ads for solar panel installation with a savings claim, included qualifying information about the type of installation, any complexities that the savings claim was dependent upon, or if referenced figures were modelled.
CAP Code (Edition 12)
3.1 3.3 3.7 3.9 3.17 3.22 3.38
