Background

This Ruling forms part of a wider piece of work on misleadingness 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 and 29 April 2026.

Summary of Council decision:

Three issues were investigated, all of which were Upheld. 

Ad description

Three paid-for Google search listings and a website for Accident Claim Helpline, an accident claims management company, seen on 4 July 2025: 
 
a. The first paid-for Google search result featured the URL “/claim/car-insurance” with a phone number. Text below stated, “In a crash? Call now to report your accident & get expert help fast. 24/7 claim support. No stress. No delays. Just help when you need it most.” 
 
b. Another paid-for Google search result featured text which stated, “Accident Helpline” with the URL “www.accident-helpline.uk/carinsurance/claims.” Headline text stated “Report Your Car Accident – Accident Reporting Line Same Day Replacement Car – Accident Specialists Waiting to Take Your Call – Accidents Only Accident Helpline UK – Providing Legal Help & Car Accident Claims Advice – Accidents Only. Available 24/7. UK Based Agents. Guaranteed Satisfaction […]”. 
 
c. Another paid-for Google search result featured text which stated, “Accident Helpline” with the URL www.accident-helpline.uk/report. Headline text stated, “Car Insurance Claims Support – 24/7 Claim Support”. Text underneath stated, “We provide independent and reliable support, ensuring a smooth and hassle-free process. No claims bonus! Our process is designed to keep it safe and sound, with no impact. Available 24/7. UK Based Agents. Guaranteed Satisfaction. 100% Committed To You.” 
 
d. The website www.accident-helpline.uk, which was the landing page for the links in ads (a), (b) and (c), featured the headline claim “Non-fault car accident Call us now!” Text below stated “[…] We proudly represent our clients following an accident ensuring we keep our clients driving […] We pride ourselves on exceptional service, caring for our clients and their vehicles offering a one call solution in the event of a Non-Fault accident.” Further text below stated “[…] Going to your car insurance provider after an accident is crazy!!!! A full tank of fuel provided by ACHL (worth £100) for your hire vehicle. […] We work for you! Like-for-Like replacement vehicle No impact on your car insurance premiums or No Claims Bonus No car insurance excess to pay. The home page featured an embedded video which opened with a driver’s car being hit from behind, then showing them going through the process of making a claim with Accident Claim Helpline and getting their vehicle repaired. The voice-over said, “Have you or your client been involved in a non-fault car accident? […] We will recover your losses directly from the third party limiting the effect on your policy with no excess to pay […] Accident Claim Helpline can deal with all aspects of your accident including a replacement hire vehicle while yours is being repaired, any uninsured losses, personal injury claims, or any medical or rehabilitation helping you get back on your feet as quickly as possible […] To date thousands of clients have trusted ACHL to handle their claims avoiding the traditional route of going through their own insurer.” Below the video and further down the page in a list of bullet-points text stated “Nothing to pay us” […] Any Additional losses suffered following your road traffic accident will be recovered on your behalf directly from the Third Party Insurer”. 
 
On a “facts-features-benefits” webpage headline text stated “What the citizens advice bureau say”. Text beneath stated “We believe using an independent Accident Claim Management company who act purely on your behalf and have your best interests at heart is the way forward. However, don’t just take our word for it, have a read of this article from the Citizens Advice Bureau by clicking this link [a web address was provided] As they say ‘The other person’s insurer won’t be acting in your best interests’”. The link took consumers to the Citizens Advice website which provided information about settling a claim via a third-party insurer. 
 
Small text at the bottom of the webpage stated “There is nothing to pay up front for our services and all costs are recovered Via the at Fault parties [sic] insurer (TPI).  Personal Injury Claims are ‘NO WIN NO FEE’ and the success fee is deducted at the end of the successful claim directly from the damages paid VIA the TPI it is not paid by our clients”. 

Issue

The ASA challenged whether:

  1. Ads (a), (b), (c) and (d) misled in relation to the nature of the service;
  2. ad (d) irresponsibly discouraged consumers from approaching their insurance provider; and
  3. ad (d) misleadingly implied Citizens Advice endorsed services such as the advertiser’s.

Response

1. Exclusive Law Ltd t/a Accident Claim Helpline said their business provided claimants who had been involved in a non-fault accident an alternative to making their claim direct with their own insurer. The ads did not mention any insurer’s names, and they did not claim to be connected with any insurer or state they acted on their behalf, which they believed consumers would be aware of when contacting them. In addition, callers would hear a message which stated, “Please press five if your call is relating to a policy matter or query relating to insurance”. If they pressed five, the message said, “Sorry the Accident Claim Helpline cannot assist with any policy related matters please redial the number on your insurers website or policy documents. The Accident Claim Helpline can only deal with non-fault road traffic claims”. The call then disconnected. In that way callers were alerted at an early stage that they had not called their insurance company and clarity regarding the nature of the services provided was disclosed. 
 
When a consumer called to speak to a claims handler, a compliance script was further used which disclosed to consumers that they were calling a regulated body, registered with the Solicitors Regulation Authority, that dealt with non-fault road traffic accidents. That was repeated in the follow-up letter sent to the consumer. If during the initial call, their call handlers identified that a consumer might be under the mistaken impression that they were talking to their insurer, the third-party’s insurer or any organisation acting on behalf of an insurer, or where there was doubt about the nature of the services provided, the call handler was required to ensure that any misunderstanding was corrected. Their complaint ratio was approximately 0.02% of all claims handled. 
 
They did not believe that consumers using their service to make a claim would negatively impact their insurance policy, as they were not utilising their policy and so did not have to pay a policy excess and their no claims bonus was unaffected. Accident Claims Helpline did not charge any costs to clients. Only in the unlikely event that a potential claim was fraudulent, dishonest, or the consumer did not cooperate in the claims process, charges may be payable by the client to the panel solicitor firm who provided the services. Such costs incurred in the claims process would be vehicle repairs, replacement vehicle hire, recovery or storage and legal fees. If any of their panel solicitors pursued a client for costs, that would only occur after the client had signed an agreement with them, but provided the client cooperated and the claim was not fraudulent, even where the claim failed, the client would not be charged any costs. 
 
The panel solicitors to who consumers were referred, those who handled the claims, operated on a “no win no fee” basis and costs were taken from the compensation paid to a successful claimant. Once a client agreed to proceed, the panel firm handled the claim through to its conclusion, liaising with all appropriate parties. No termination fee was payable by the claimant, and they intended to add that information to their website. 
 
In non-fault claims, the third-party’s insurer might dispute liability, however, their panel solicitors would provide support through that process. Where liability was disputed by the third-party’s insurer, the claim would be considered as defended, but clients would still not be invoiced for that by the panel solicitors unless the client failed to cooperate or knowingly provided false information. 
 
They had reviewed the small text at the end of the page on their website and made it larger and more prominent and were also reviewing the fee which was deducted from a successful personal injury claim. 
 
2. Accident Claim Helpline said they believed their ads met Google’s compliance requirements but had deleted the claim “Going to your car insurance provider after an accident is crazy!!!!” from their website. They said it was never their intention to irresponsibly discourage consumers from approaching their insurance provider. They recognised that consumers had freedom to decide how they wished to pursue a claim and such language would not be used in future. 
 
Google Ireland confirmed that the ad in question was served through one of their advertising products. They said under the terms agreed to by advertisers, it was the advertiser’s responsibility to abide by Google’s policies and applicable law, including the CAP Code. 
 
3. Accident Claim Helpline said they did not link their website to any claim that the Citizens Advice Bureau (CAB) endorsed their services. However, they had deleted the section on their website which referenced the CAB.

Assessment

1. Upheld

Ads (a), (b) and (c) included the claims, “In a crash? Call now to report your accident & get expert help fast”, “Report Your Car Accident – Accident Reporting Line […] Accident Specialists Waiting to Take Your Call” and “Car Insurance Claims Support – 24/7 Claim Support We provide independent and reliable support”. 
 
The ASA considered that consumers involved in an accident, were generally likely to be in a hurry to get assistance, and might search online for such help shortly, if not immediately, after the accident, when they were likely to be particularly vulnerable. While the claims were ambiguous about the service offered, we considered that consumers were likely to understand from ads (a), (b) and (c), that they could contact Accident Claim Helpline in the event of a car accident for assistance in making an insurance claim. We further considered the ads suggested that anyone involved in?an accident?would be able to use Accident Claim Helpline’s?services.  However, only ad (d), the landing page, which stated, “Non-Fault car accident Call us now!”, made clear that they handled only non-fault accident claims. Ads (a), (b) and (c) did not make the non-fault accident limitation clear and we considered they instead implied that Accident Claim Helpline dealt with all accident claims. 
 
Whilst the search result ads (a), (b) and (c) were limited by space, information about Accident Claim Helpline handling only non-fault claims was material information that could be easily and succinctly conveyed and should have been included in the search ads. In addition, ad (a) included a phone number and, as such, consumers who saw ad (a) might immediately contact the advertiser by phone instead of clicking the URL which would take them to the information on the non-fault limitation included on the landing page. 
 
Ad (c) stated, “No claims bonus! Our process is designed to keep it safe and sound, with no impact.” Ad (d) stated, “We believe using an independent Accident Claim Management company who act purely on your behalf and have your best interests at heart is the way forward”. Further down the page in ad (d), text in bullet points stated, “Nothing to pay us” and “Any Additional losses suffered following your road traffic accident will be recovered on your behalf directly from the Third Party”. We considered that consumers would understand?from that that?they would not be liable for any cost in connection with making a claim because the costs were recovered from the third-party’s insurer.  We considered those claims gave the impression that it was always financially more advantageous for consumers to use the advertiser’s service to handle their accident claim than their insurer. 
 
However, we understood that consumers who claimed through an accident claims management company could incur additional costs that they would not usually be liable for under their insurance policy. We understood that consumers using such services became liable for costs when they entered into a credit agreement, for example, when a replacement car was arranged. While typically costs would be met by the third-party driver’s insurer, that could not be guaranteed. For example, the fault for the accident might be disputed and need to be established, not necessarily successfully, or the level of car hire charges might be disputed. In cases where the third-party’s insurer would not pay, we understood that consumers could be responsible for the costs already incurred, such as vehicle recovery, repairs, storage or a replacement vehicle. However, the ads did not make clear the risk of potential costs from using accident claims management companies. 
 
The small text at the bottom of ad (d) stated, “There is nothing to pay up front for our services and all costs are recovered Via the at Fault parties [sic] insurer (TPI).  Personal Injury Claims are ‘NO WIN NO FEE’ and the success fee is deducted at the end of the successful claim directly from the damages paid VIA the TPI it is not paid by our clients.”  We considered the position of that text meant that consumers were likely to overlook it.  We also considered that while it implied that no costs were payable to Accident Claim Helpline, it also did not make clear to any consumers who might have seen it the risks or costs associated with making a claim using their services if a claim was disputed or unsuccessful, or how costs were recovered and fees deducted via the “no win no fee” arrangement. 
 
The voice-over in the video in ad (d) stated, “We will recover your losses directly from the third party limiting the effect on your policy with no excess to pay.” We considered that consumers may not watch the video but even if they had, it also did not make clear the potential costs that consumers might have to pay beyond those that were recoverable from the third party. We considered the?implication in ad (d)?that there would be no cost to the consumer, when that was not always the case, was likely to mislead consumers.? 
 
We considered the risk of consumers incurring additional costs as a result of claiming through an accident management company instead of their insurance provider, was also information that was material to understanding the nature of the service and should have appeared in the search ads, or clearly on the landing page ad (d), not least given the potentially confusing use of the word “insurance” in the advertiser’s URL. 
 
Because the ads did not make that information clear to consumers, and ads (a), (b) and (c) did not make the non-fault limitation clear, we concluded that they misled in relation to the nature of the service being offered. 
 
On that point, ads (a), (b) (c) and (d) breached CAP Code (Edition 12) rules 3.1 and 3.3 (Misleading advertising), and 3.9 (Qualification).

2. Upheld

Ad (d) featured the claim, “Going to your car insurance provider after an accident is crazy!!!!”. We considered that claim implied that consumers were not required to notify their insurance provider after an accident and that it was always more beneficial to avoid using their own insurer to make a claim. 
 
While we recognised consumers might choose to use an accident claims management company to handle a claim, we understood that most insurance policies required policyholders to notify their insurer of any accident, regardless of whether any damage was caused to their vehicle, irrespective of whether a claim was made, or of who was at fault. We further understood that failing to notify an insurer could affect future cover. 
 
We noted that the webpage stated, “A dedicated claim handler throughout your process, who will handle interactions with your car insurance” which suggested that there might be some contact with the consumer’s insurer. However, because that statement appeared in smaller text in a list of bullet points beneath the large and prominent heading, “Going to your car insurance provider after an accident is crazy!!!!”, we considered it did not alter the impression that consumers should not notify their insurer but should instead use the advertiser’s service to handle their claim. 
 
We welcomed Accident Claim Helpline’s assurance that the claim had been removed and that similar claims would not be used in future. However, because at the time the ad appeared it suggested that consumers should avoid informing their insurer about an accident and that it was advantageous for them to do so, we concluded that ad (d) was misleading and irresponsibly discouraged consumers from contacting their insurance provider after an accident. 
 
On that point, ad (d) breached CAP Code (Edition 12) rules 1.3 (Social responsibility) and 3.1 (Misleading advertising).

3. Upheld

Ad (d) stated, “We believe using an independent Accident Claim Management company who act purely on your behalf and have your best interests at heart is the way forward. However, don’t just take our word for it, have a read of this article from the Citizens Advice Bureau by clicking this link”. Under the prominent heading, “What the citizens advice bureau say” the ad stated, “As they say, “the other person’s insurer won’t be acting in your best interests”. 
 
We considered those claims were likely to be interpreted by consumers to imply that the CAB approved or endorsed the services offered by accident claim management companies similar to the advertiser, as opposed to the consumer using their insurer. Further, because the ad featured a prominent reference to CAB and included a link to an article on their website, we considered readers were likely to pay greater attention to, and place greater trust in the ad’s message. However, we understood that the linked article provided only general insurance claims information and was not an endorsement for using the services of accident claims management companies as the claim implied. 
 
We acknowledged that Accident Claim Helpline had removed the references to the CAB from their website. However, because at the time the ad appeared, Accident Claim Helpline gave the impression that the CAB endorsed the use of accident claims management companies above insurers, when that was not the case, we concluded that the ad was misleading. 
 
On that point, ad (d) breached CAP Code (Edition 12) rule 3.1 (Misleading advertising).

Action

Ads (a), (b), (c) and (d) must not appear again in the form complained of. We told Exclusive Law Ltd t/a Accident Claim Helpline to ensure they made clear to consumers the nature of their service, including in relation to non-fault accidents, that they did not imply that there was no cost to the consumer if that was not the case, and did not irresponsibly discourage consumers from approaching their motor insurance provider. We also told them not to imply that the use of accident claims management companies had been approved by any public or other body if that was not the case.

CAP Code (Edition 12)

1.3     3.1     3.3     3.9    


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