Background
This Ruling forms part of a wider piece of work on misleadingness and imitation 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 2026.
Ad description
Three paid-for Google search listings and three websites for Report Incident, an accident claims management company, seen on 4 July 2025:
a. The first paid-for Google search result featured the URL “www.e.sure-report-incident.co.uk” with headline text below which stated “Contact Us – Car Insurance Claims”. Further text stated “Call our team for immediate assistance and try our independent service. Has your vehicle been involved in a road traffic incident? Comprehensive Service”.
b. The second paid-for Google search result featured the URL “www.hastings.report-incident.co.uk” with headline text below which stated “Call our Team – Report an Accident Been involved in a road traffic accident? […]”.
c. The third paid-for Google search result featured the URL “www.church.hill-report-incident.co.uk” with headline text below which stated “Contact Us – Car Insurance Claims”. Further text stated “Call our team for immediate assistance and try our independent service. Has your vehicle been involved in a road traffic incident? Comprehensive Service”.
d. The website, www.sure-report-incident.co.uk/report6/ was the landing page for the link in ad (a). The website initially featured a pop-up box webpage which stated “Report an Incident If you have been involved in a road traffic incident, make sure you are in a safe place and then call our team as soon as possible” and displayed a phone number. When that page was clicked, the website homepage appeared which featured text which stated “REPORT INCIDENT” above an image of a driver on the phone beside a damaged car. Text beneath the image stated “Keep your insurance CLEAN! Try our comprehensive service following a road traffic incident and leave your insurance completely claim free. Beneath animated images of a tow truck tools and a car, text stated “RECOVERY No matter where you are in the UK, call us for speedy and reliable roadside recovery. VEHICLE REPAIRS We provide a vehicle repair service to get you straight back on the roads. REPLACEMENT CAR Get a like for like replacement vehicle for whilst yours is off the road”. Small text at the bottom of the page stated “The services we provide are completely independent from your own insurance company. Our aim is to help keep your insurance costs from rising.” Further text which stated “Contact us”, “Privacy policy” and “Terms and conditions” were not hyperlinked and provided no further information.
e. The website, www.report-incident.co.uk/report6/ was the landing page for the URL in ad (b) and featured the same content, including the pop-up box, as ad (d).
f. The website, www.report-incident.co.uk/report6/ was the landing page for the URL in ad (c) and featured the same content, including the pop-up box, as ad (d).
Issue
The ASA challenged whether the ads, by implying they were for a car insurance provider, falsely implied that the marketer was acting for purposes outside its business and did not make clear their commercial intent.
Response
Dean Harrison t/a Report Incident did not respond to the ASA’s enquiries.
Assessment
Upheld
The ASA was concerned by Dean Harrison’s lack of response and apparent disregard for the Code, which was a breach of CAP Code (Edition 12) rule 1.7 (Unreasonable delay). We reminded them of their responsibility to respond promptly to our enquiries and told them to do so in future.
The CAP Code stated that marketing communications must not falsely claim or imply that the marketer is acting as a consumer or for purposes outside its trade, business, craft or profession; marketing communications must make clear their commercial intent, if that was not apparent from the context.
We understood that Report Incident was an accident claims management company dealing with non-fault accidents. It had no direct connection to either E-sure, Hastings or Churchill insurance companies and therefore could not assist customers of those companies in making a claim on their insurance policy following an accident.
Ads (a), (b) and (c) featured the web addresses “www.e.sure-report-incident.co.uk”, “www.hastings.report-incident.co.uk” and “www.church.hill-report-incident.co.uk”. The ads also featured the prominent claims “Contact Us – Car Insurance Claims […]” and “Call our Team – Report an Accident”. E-sure, Hastings Direct and Churchill were well known as insurance companies, and we considered that the ads presented themselves as being from those companies. We considered consumers were therefore likely to understand that by clicking on those links, they could contact the E-Sure, Hastings Direct and Churchill claims departments following a motor accident.
Ads (d), (e) and (f), the website landing pages for the links in ads (a), (b) and (c), had the web addresses “www.sure-report-incident.co.uk/report6/”, “www.report-incident.co.uk/report6/” and “www.hill-report-incident.co.uk/report6/”. Additionally, they all featured an initial pop-up box webpage which stated “Report an Incident” with a phone number to call.
We considered those claims further contributed to the impression that customers of E-Sure, Hastings Direct and Churchill insurance would be able to begin processing their accident claims through those websites, which was not the case. We noted that ads (a) and (c) stated, “Call our team for immediate assistance and try our independent service”, but that appeared under the more prominent claim “Contact Us - Car Insurance Claims”. The landing pages for ads (d), (e) and (f), included the statement, “The services we provide are completely independent from your own insurance company”. However, that text appeared only at the bottom of the page, after clicking through from the pop-up box. We considered the lack of prominence of both claims meant consumers were likely to overlook that text and that in any event it was insufficient to alter the overall impression of the ads, that consumers were contacting an insurer directly.
We considered further that consumers were likely to be unaware of the nature of the service being offered in the ads, an accident claims management company dealing with non-fault accidents, and of the potential costs and risks of not contacting their insurer. For example, we understood there were potential costs associated with a replacement vehicle, which we understood was generally provided on a credit hire basis, costs for vehicle repairs or storage costs charged by the businesses they used. In addition, we understood there was a risk of loss of specific benefits under a consumer’s own insurance policy, or of impact on existing insurance cover if they did not notify their own insurer of an accident, irrespective of whether a claim was made.
Because Report Incident misleadingly presented itself as insurance providers and did not make clear they were an accident claims management company, we considered the ads falsely implied they were acting for purposes outside their trade, business, craft or profession and did not make clear their commercial intent. We concluded that the ads breached the Code.
Ads (a), (b), (c), (d), (e) and (f) breached CAP Code (Edition 12) rule 2.3 (Recognition of marketing communications).
Action
The ads must not appear again in the form complained of. We told Dean Harrison t/a Report Incident to ensure they did not falsely imply they were acting for purposes outside of their trade, and to ensure that their future marketing communications made clear that they were a motor accident claims management company. We referred the matter to CAP’s Compliance team.
