Background
This Ruling forms part of a wider group of investigations on HGV (Heavy Goods Vehicle) training operators. See also related rulings published on 22?April 2026.
Summary of Council decision:
Two issues were investigated, both of which were Upheld.
Ad description
Websites for Easy as HGV Ltd and associated group companies, a heavy goods vehicle (HGV) training services provider, seen in August 2025:
a. A website for Easy as HGV, www.easyashgv.co.uk, featured a page that included the claims, “With a network of over 90 training centres” and “Easy as HGV provides high quality training …”.
b. A website for HGV Driving Centre, www.hgvtrainingcentre.co.uk, featured the claim, “We ensure high pass rates with our unique Pass Protection service”.
c. A website for surreyandhampshirehgvtraining.co.uk included the claim, “We provide high quality HGV training …”.
Issue
JCoates HGV Services Ltd challenged whether:
1. the claim “We ensure high pass rates with our unique Pass Protection service” in ad (b) was misleading and could be substantiated; and
2. ads (a) and (c) falsely implied that the marketer was acting for purposes outside its trade, business, craft or profession.
Response
1. Easy as HGV Ltd said pass protection was an optional add-on product selected at the time of booking. It provided one additional practical test attempt together with 1 to 2 hours of refresher training prior to that retest where required. Pass protection was designed to provide structured support and reduce the financial and administrative burden associated with a retest.
The wording in the ad was intended to describe the structured support provided where a retest was required. It was not intended to imply certainty or a guaranteed outcome. They monitored candidate outcomes across their partner training network for quality assurance purposes and based on aggregated internal operational data covering 2025 the overall pass rate across first and second attempts for their candidates who purchased pass protection was on average 72%. That figure reflected overall outcomes across first and (where applicable) second attempts for candidates who purchased pass protection. For context, DVSA published figures for the same period that indicated an overall LGV vocational test pass rate of approximately 61% across all attempts in Great Britain. They recognised, however, that the DVSA figure represented overall pass rates across all attempts and was therefore not directly comparable.
Easy as HGV said they had amended the claim.
2. Easy as HGV said they operated as a full-service driver training coordination provider. Customers contracted directly with them for a packaged service that managed the end-to-end process of obtaining an HGV licence. They said their service included explaining licence categories and the licensing process, supplying and guiding customers through provisional licence applications, providing theory test revision materials, advising on and arranging relevant CPC qualifications, advising on suitable training locations and dates, coordinating practical driver training and test arrangements, re-booking tests where required and providing post-qualification CV preparation and recruitment support.
Practical driver training was delivered through a nationwide network of approved partner training providers. Those providers delivered the on-road instruction component, while they retained responsibility for coordinating the customer journey and managing the administrative and support elements of the service. Customers contracted with them for the managed package and they coordinated delivery through their approved network and retained oversight of the overall customer experience.
As part of their quality control processes, they maintained regular contact with partner training locations and kept internal records of customer test outcomes. That enabled them to monitor performance trends and to provide informed guidance to customers when discussing available training locations. They said revenue was generated through the service fee paid by the customer for the overall package. They did not receive separate referral commissions from training providers outside of that structure. They said their website stated, “We coordinate the full licence process, with training delivered through 92+ trusted centres.” That wording appeared on key pages including the homepage and quote process.
Following receipt of the complaint, they had reviewed and updated the wording across the relevant pages and within their terms and conditions.
Assessment
1. Upheld
The ASA considered that consumers would likely understand the claim in ad (b), “We ensure high pass rates with our unique Pass Protection service” to mean that HGV Driving Centre could reliably deliver a strong likelihood of them passing their HGV licence test by using their pass protection service. We considered the claim was likely to be understood as referring to more than support, and as relating to a likely positive test outcome.
We understood that pass protection was an optional add-on selected at the time of booking, which provided one additional practical test attempt and one to two hours of refresher training before that retest, where required. We considered that information was material to understanding what pass protection offered, however, the claim in the ad did not make that information clear.
Easy as HGV provided pass protection pass rate data for January to December 2025 which showed that out of 679 tests taken, 489 passes were achieved with an overall pass rate of 72% for candidates who had purchased pass protection, measured across first and second attempts. We acknowledged this data suggested that many of the candidates who purchased pass protection did go on to pass within two attempts. However, we considered a 72% pass rate, incorporating those who took two attempts to pass, was unlikely to be in line with consumer expectations of the claim that Easy as HGV “ensure[d]” high pass rates”.
Because we considered the ad did not clarify how pass protection worked and was likely to exaggerate what pass protection could achieve, we concluded the ad was misleading.
On that point, ad (b) breached CAP Code (Edition 12) rules 3.1 and 3.3 (Misleading advertising) and 3.7 (Substantiation).
2. Upheld
We considered the claims in ads (a) and (c), “Easy as HGV provides high quality training …” and in that context “With a network of over 90 training centres”, and “We provide high quality HGV training …”, would likely be understood by consumers to mean that Easy as HGV provided HGV training, through its own training centres and instructors.
We understood that the practical driver training was delivered through a nationwide network of approved partner training providers and that part of Easy as HGV’s role was to coordinate or arrange training delivered by third-party providers, for which it received a service fee from consumers, rather than deliver that practical tuition itself.
However, we considered consumers were likely to think they were contracting with a training provider delivering instruction directly, rather than a business arranging training delivered by others. We therefore concluded that ads (a) and (c) misleadingly implied that Easy as HGV were acting for purposes outside their business and therefore breached the Code.
On that point, ads (a) and (c) 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 Easy as HGV Ltd to ensure that pass rate claims were not misleading and could be substantiated. We also told them to ensure that they did not falsely imply they were acting for purposes outside their business.
