Background
This ruling forms part of a wider piece of work on advertising for greener heating and insulation products. The ad was identified for investigation following intelligence gathering by our Active Ad Monitoring system, which uses AI to proactively survey ads in specific sectors.
Summary of Council decision:
Two issues were investigated, both of which were Upheld.
Ad description
A paid-for Meta ad, seen in May 2025, for Good Energy featured an image with superimposed text that stated, “You can save up to £1,341 in bills”. A caption accompanying that stated, “Did you know low-carbon homes can save over £1000 a year in bills? According to research [...] homes with improvements such as solar panels, a battery, insulation and a heat pump cost less to run […]”.
Issue
The ASA challenged whether:
- the claims “Did you know low-carbon homes can save over £1000 a year in bills” and “You can save up to £1,341 in bills” were misleading and could be substantiated; and
- the ad had failed to make clear all significant limitations and qualifications.
Response
1. & 2. Good Energy Ltd stated that the ad outlined the low-carbon improvements needed to achieve the savings. They believed that a consumer would understand both the basis of the claimed figures and the reference to a low-carbon home to mean a home which had solar panels, battery storage, and heat pumps through Good Energy.
They stated that the ad was designed to show the potential savings consumers could make to their housing running costs with low-carbon improvements. The ad stated that households with low-carbon technology could save up to £1,341 in bills and made clear that the claim was based on a report by a charity focused on accelerating the transition to carbon-free homes and renewable energy across the UK.
Good Energy explained that while the report related primarily to new build homes, they believed that retrofit properties were capable of achieving the same benefits. They provided a summary of their internal customer data that demonstrated a significant proportion of their customers with low carbon technology upgrades were able to make savings equal to, or in excess of the amounts outlined in the ad.
Assessment
1. & 2. Upheld
The CAP Code stated that before distributing or submitting a marketing communication for publication, marketers must hold documentary evidence to prove claims that consumers were likely to regard as objective and that were capable of objective substantiation. It additionally required that price claims such as “up to” must not exaggerate the availability or amount of benefits likely to be obtained by the consumer. The Competition and Markets Authority (CMA) guidance “Marketing green heating and insulation products: Consumer law compliance advice for businesses” (the CMA Guidance) stated that “up to” claims should reflect that at least a significant proportion of consumers would be likely to achieve the stated outcome and that it reflects the range of factors which impact product performance. The ASA had regard to the guidance in assessing the ad against the CAP Code.
The ad featured savings claims that stated, “Did you know low-carbon homes can save over £1000 a year in bills” and “You can save up to £1,341 in bills”. Text in the ad’s caption stated, “According to research [...] homes with improvements such as solar panels, a battery, insulation and a heat pump cost less to run [...]”. We considered consumers would interpret the savings claims, within the overall context of the ad, as meaning that a significant proportion of consumers who had any one of the low-carbon home upgrades on their home could achieve savings of £1,341 on their energy bill annually. We acknowledged Good Energy’s view that consumers would understand “low-carbon homes” to mean a home which had installations of all the products referred to in the ad. However, we considered that the wording of the claim that followed – “homes with improvements such as solar panels, a battery, insulation and a heat pump cost less to run” – suggested that a home only had to have a minimum of one such improvement in order to be classed as a low-carbon home and be capable of obtaining the level of savings claimed. We therefore assessed the ad on that basis.
We reviewed the report that Good Energy referred to. It outlined modelled annual running cost saving calculations for three different combinations of low-carbon housing upgrades and applied each combination to different types of newly built housing structures. We understood that the option being relied upon for the purposes of the ad’s claim centred around a property having the following features: solar panels, heat pump, wastewater heat recovery, increased airtightness, decentralised mechanical ventilation (dMEV) system and battery storage. Additionally, the savings were based on a three-bedroom, semi-detached newly built house and had been compared against the running costs of that type of house where only a heat pump was installed. Further, while the ad referred to “insulation”, the report instead focused on “airtightness”, which we understood had a broader definition and was likely to include additional features including, but not limited to, seal penetrations and airtight windows and doors. We considered that the basis of the savings claim, including the type and size of home, the full range of low-carbon upgrades, and that the savings figures were modelled, was material information that was likely to affect a consumers’ understanding of the ad’s overall message and was therefore required to be stated in the ad, so that consumers could proceed further into the consumer journey of obtaining low-carbon home upgrades 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. We understood the ad’s landing page, one click away, repeated the £1,341 savings claim and asterisked to text that stated, "Solar panels, a heat pump, high-grade insulation and battery storage would save someone living in a typical three-bedroom, semi-detached newly built house £46,612 over a 25-year mortgage term according to modelling [...]". Consumers did not need to read all the information on the page in order to proceed through the process of getting further information or a quote about low-carbon home upgrades.
We reviewed Good Energy’s summary of their internal customer data. It outlined the running cost savings for each individual product installation. A significant proportion of consumers, who had multiple low-carbon home upgrades, were able to achieve a saving of at least £1,341 on their energy bills annually. However, because the level of savings were dependent on customers installing multiple upgrades, we considered the summary did not adequately substantiate the savings claims as they were presented in the ad.
We therefore concluded that material information had been omitted from the ad and that the claims “save over £1000 a year in bills” and “you can save up to £1,341 in bills” had not been substantiated and were likely to mislead.
The ad breached CAP Code (Edition 12) rules 3.1, 3.3 (Misleading advertising), 3.7 (Substantiation), 3.9 (Qualification), 3.17, 3.22 (Prices) and 3.38 (price comparisons).
Action
The ad must not appear again in the form investigated. We told Good Energy Ltd to ensure that any “up to” saving claims could be appropriately substantiated. We also told them to ensure their ads that made “up to” saving claims about greener home installations included all material information, such as any qualifications about the type of installation, any complexities that the saving was dependent upon, or if referenced savings figures were modelled.
CAP Code (Edition 12)
3.1 3.3 3.7 3.9 3.17 3.22 3.38
