Background
This Ruling forms part of a wider piece of work on advertising for greener heating and insulation products. The ads were identified for investigation following intelligence gathering by our Active Ad Monitoring system, which uses AI to proactively survey ads in specific sectors. See also related rulings published on 6 August 2025.
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.
Ad description
A paid-for Google ad for EDF seen on 12 February 2025 featured an image of an air source heat pump. Text stated \"Get A £7,500 Grant – EDF Air Source Heat Pumps\" and “Get a Free Quote in Minutes […]”.
Issue
The ASA challenged whether the ad was misleading because it omitted material information about the government funding available for installing heat pumps.
Response
EDF Energy Ltd t/a EDF said the ad linked through to one of three landing pages on their website which contained information about the government funding for heat pumps. All relevant material information about the government funding’s eligibility criteria was made clear on those landing pages. Consumers would understand that by clicking on the ad they would land on a page that would explain what they needed to do to get a £7,500 grant.
Assessment
Upheld
The CAP Code stated marketing communications must not mislead the consumer by omitting material information. Guidance from the Competition and Markets Authority (CMA) advised that if marketers referred to government funding anywhere in their marketing, they should be clear that access to funding was subject to a consumer meeting the eligibility criteria. The ASA had regard to the guidance in assessing whether the ad had complied with the CAP Code.
We understood the “£7,500 Grant” the ad referred to was the Boiler Upgrade Scheme (BUS) for consumers in England and Wales and the Home Energy Scotland Grant and Loan (HESG&L) for consumers in Scotland. There were a number of eligibility criteria that consumers needed to satisfy in order to qualify for funding for a heat pump and those differed between the BUS and HESG&L. Under the BUS, they included that the applicant must be a homeowner of a non-new build house in England or Wales with a valid Energy Performance Certificate (EPC), replacing an existing fossil fuel heating system and only receiving funding from one source of public funds. Under the HESG&L, the applicant must own or jointly own a property in Scotland as either their only or principal private residence, the property must be registered with the Scottish Assessors Association as paying domestic council tax rates and the property must have a valid EPC.
The ad stated, “Get A £7,500 Grant – EDF Air Source Heat Pumps”. While the ad referred to a “£7,500 grant” (which would be understood as referring to government funding), it did not include information about eligibility criteria having to be satisfied in order to receive the funding. In the absence of that information, we considered the ad gave the impression that all consumers were eligible for £7,500 of government funding to have a heat pump installed.
We acknowledged that the ad linked to landing pages, one click away, which referred to the available funding and which included some information about eligibility criteria. While information about the eligibility criteria was on the landing pages, consumers would have only been aware of it if they read that section of those pages, which was not necessary to obtain a quote to have a heat pump installed. However, we considered that the fact the funding was subject to meeting specific criteria was material information that was likely to affect consumers’ understanding of the ad’s overall message. It was, therefore, required to be stated in the ad, so that consumers could proceed further into the consumer journey of obtaining a quote for a heat pump installation with EDF 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.
The ad gave the impression consumers would be automatically eligible to receive a government grant of £7,500 and it did not make clear the government funding for a heat pump was subject to eligibility.
We considered that was material information that should have been included. Because the ad omitted material information, we concluded it was likely to mislead.
The ad breached CAP Code (Edition 12) rules 3.1, 3.3 and 3.9 (Misleading advertising).
Action
The ad must not appear again in the form investigated. We told EDF Energy Ltd t/a EDF to ensure their ads that referred to the government grants for heat pumps included all material information, including that eligibility criteria applied.
