Background
This Ruling forms part of a wider piece of work on advertising for greener heating and insulation products. The ad was identified for investigation following intelligence gathering by our Active Ad Monitoring system, which uses AI to proactively survey ads in specific sectors.
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 the ASA’s assessment of the ad that formed the subject of this ruling was carried out before 7 April 2025 the ASA considered the ad 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.
Summary of Council decision:
Two issues were investigated, both of which were Upheld.
Ad description
A paid-for Bing search ad for Contact Solar, a solar panel installation company, seen 27 February 2025, stated “£5,995 Fully Installed Solar - No Deposit Needed”. Further text below stated, “Get your free, instant quote".
Issue
The ASA challenged whether the:- claim “£5,995 Fully Installed Solar” was misleading and could be substantiated; and
- ad had failed to make clear all significant limitations and qualifications.
Response
1. & 2. Contact Solar Ltd said they expected consumers to interpret the ad as meaning they could have a solar panel system installed for £5,995. At that price point, consumers received a 4.3-kilowatt (kW) panel system, a fixing kit, access to an online monitoring portal, warranty, and scaffolding.
They said all 4.3 kW panel installations in 2025 had cost £5,995 or less, and that the only time that price had been exceeded was when a consumer opted to have a battery installed, purchased additional accessories, or when the consumer had a non-standard supply arrangement, such as three phase rather than single phase – three phase provides a more balanced distribution of electricity to a property and can support a higher load than single phase.
Assessment
1. & 2. Upheld
The CAP Code stated that marketing communications must not mislead by omitting material information. It also stated that price claims must not mislead by omission, undue emphasis or distortion. The Competition and Markets Authority’s (CMA) guidance on ‘Marketing green heating and insulation products’ stated the prices that consumers see should be accurate and give a realistic indication of what they are likely to pay for a product, and that headline prices must be truthful and clear. The guidance also stated that any important qualifications should be presented clearly and prominently as close to the headline price as possible, so that a consumer could easily see them. We had regard to the guidance in assessing the ad against the CAP Code.
The ad stated “£5,995 Fully Installed Solar - No Deposit Needed”. We considered consumers would understand from the absolute pricing claim that Contact Solar charged no more than £5,995 for solar panels and their installation.
The ad linked through to Contact Solar’s website which outlined the prices of the different solar panel packages they sold, including a 4.3 kW package for £5.995 and that their prices were subject to the consumer’s circumstances and Contact Solar’s terms and conditions. We understood they sold packages at a higher wattage than 4.3 kW, which could be necessary for homes with higher electricity usage, and the starting price of those packages was greater than £5,995. Further, for 4.3 kW packages, the £5,995 price referred to in the ad could be exceeded if the consumer’s property had additional factors that made installing the panels more complex, such as if they had a three-phase rather than single-phase electric supply. We considered this was material information that was likely to affect consumers’ understanding of the paid-for Bing ad’s price claim 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 solar panel installation with Contact Solar in an informed manner. The ad itself had used 219 characters, we considered that was sufficient space to make clear the package details the price claim referred to and that the price could be affected by a consumer’s individual circumstances.
We acknowledged that in 2025 Contact Solar had sold 4.3 kW solar panel packages at or below £5,995. However, that price had been exceeded when a consumer’s property had complicating factors, such as a three-phase rather than a single-phase electric supply, or if the consumer had purchased a higher wattage package.
We therefore concluded material information had been omitted from the ad, and in the context of the ad itself, the claim “£5,995 Fully Installed Solar - No Deposit Needed” had not been substantiated and was likely to mislead.
The ad breached CAP Code (Edition 12) rules 3.1, 3.3, (Misleading advertising) 3.7, (Substantiation) 3.9 (Qualification) and 3.17 (Prices).
Action
The ad must not appear again in the form investigated. We told Contact Solar Ltd to ensure their ads for solar panel installations included all material information, such as any qualifications regarding important details about the relevant solar panel package or any complexities upon which the price was dependent. We also told them to ensure price statements for solar panel installations could be appropriately substantiated.
