Background
This ruling forms part of a wider piece of work on social responsibility in ads for credit offered for Christmas.
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 18 March 2026.
Ad description
A paid-for Facebook ad for Eastern Savings & Loans, a credit union, seen in November 2025, stated, “Before you start Black Friday Shopping, check out our affordable Christmas Loans. Pay back your credit union Christmas Loan in a way that suits you; we offer weekly, monthly or four weekly repayment options.”
The ad featured a black graphic that stated, “BEFORE BLACK FRIDAY SHOPPING” and “CHRISTMAS LOANS”. Smaller text stated, “FROM Eastern Savings & Loans” alongside the brand name and logo. The image also showed a person sitting on a rug with a tablet. Below the image, text stated, “Loans From £300. Manage your finances with flexible repayments and save for next year …”.
Issue
The ASA challenged whether the ad was irresponsible because it encouraged taking out a loan to make non-essential purchases.
Response
Eastern Savings and Loans Credit Union Ltd (Eastern Savings & Loans) said social responsibility was important to them and that was reflected in their policies. For instance they included a “Financial Wellbeing” section on their website to assist their members. In addition all applications underwent an assessment of the affordability of credit to determine that loan repayments would be affordable. They explained that 55 to 75 per cent of loan applications for new members were rejected due to that assessment. They said further that they were committed to encouraging their members to save money and that was evidenced by those who borrowed for Christmas, subsequently becoming savers for Christmas using their services.
They said that their advertising targeted short term, small loans, of approximately £400 or less, which, in the absence of a credit union, would ordinarily be provided by high-cost lenders. Therefore, their advertising was not intended to create demand for credit, which had always existed leading up to Christmas, but to displace the use of high-cost and illegal lending through ethical lending.
They stated that they received applications for Christmas loans from October onwards. Black Friday happened to fall in the middle of the period before Christmas and allowed consumers to purchase Christmas gifts in advance and, if they were careful shoppers, to purchase at reduced prices. They said that it was up to consumers to decide what their priorities were for the Christmas season. However, they were aware that parents purchased both essential clothing and laptops, necessary for school work, for their children at Christmas using their loans. They said further that there was no evidence that their members bought non-essential items in the Black Friday sales. The ad therefore did not encourage the purchasing of non-essential products.
They said they made no specific claims in the ad and just suggested that consumers consider their loans before they began Christmas shopping, which could have included the opportunity to utilise Black Friday sales to make purchases. The ad made no reference to “hassle free” or “more enjoyable” Christmas, for example.
They said that at the time in question they had run other paid for ads providing links to blog articles titled “Ideas for Christmas on a Budget” and “Using Buy Now Pay Later for Christmas” which aimed to inform potential members of the risks of irresponsible spending. They also promoted, in non-paid for space, links to the government’s “Money Helper” website.
Assessment
Upheld
The ASA acknowledged that credit unions were often the only option of financial assistance for many consumers who would not be considered creditworthy by mainstream banks and who might otherwise turn to high-cost or illegal money lenders to obtain credit. We also understood that credit unions provided services which helped their members build their credit rating. However, as with any credit provider, consumers would be required to repay what they had borrowed, with interest, and there would be consequences if repayments were not made on time. The ad promoted Christmas loans from Eastern Savings & Loans and we therefore focused our assessment on whether the ad presented that product responsibly.
The ad stated, “Before you start Black Friday shopping…” and “BEFORE BLACK FRIDAY SHOPPING”, and also referenced Christmas loans. We considered the references to “before Black Friday” might imply that the ad was addressing people who had already decided to shop for Christmas purchases during Black Friday. However, regardless of whether that was the case, we considered that consumers who had not previously intended to obtain credit to shop during Black Friday, or for Christmas, may have been encouraged to do so as a result of the ad’s messaging. We acknowledged Christmas was a time when people did need extra money to cover additional costs such as buying gifts, extra food to celebrate Christmas Day or travel expenses incurred by visiting family. We also noted that the ad made no reference, beyond Black Friday, to specific purchases. However, we understood that Black Friday typically offered savings on predominantly non-essential products such as technology, beauty and clothing and, as such, considered the ad encouraged taking out credit for such purchases.
Therefore, because the ad encouraged taking out credit for non-essential purchases, we concluded that it was irresponsible.
The ad breached CAP Code (Edition 12) rule 1.3 (Responsible advertising).
Action
The ad must not appear again in the form complained of. We told Eastern Savings and Loans Credit Union Ltd to ensure that future ads did not irresponsibly encourage the purchase of non-essential items through the use of credit.
