Background
This Ruling forms part of a wider piece of work on health monitoring apps. The ad was 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 17 June 2026.
Summary of Council decision:
Two issues were investigated, both of which were Upheld.
Ad description
Two paid-for in app-ads for HealthTracker Apps t/a Blood Pressure Monitor App, a health app, seen in October and November 2025:
a. An in-app ad, seen within the host app “Blood Pressure Monitor” (Haniya Apps) on 25 October 2025, showed a Google Play-style app listing headed “Blood Pressure Monitor App”.
The image showed a digital monitor-style display with the labels “SYS mmHg”, “DIA mmHg” and “PUL”, alongside the readings 128, 65 and 65. The “PUL” reading appeared next to a red heart icon. A vertical colour chart appeared on the left, graded from dark green at the top to red at the bottom, with an arrow pointing to an amber section in the lower half.
b. An in-app banner ad, seen in the Blood Pressure Diary (Health & Fitness AI Lab) on 12 November 2025, included the same digital monitor-style image as ad (a), alongside the title “Blood Pressure Monitor App” and the subheading “Observe your health status anytime, anywhere”.
Issue
The ASA challenged whether the:
1. ads made unauthorised medical claims that breached the Code; and
2. claims that the app could monitor blood pressure and heart rate in ads (a) and (b) were misleading and could be substantiated.
Response
1. & 2. HealthTracker Apps t/a Blood Pressure Monitor App said the ads were dynamically generated by Google Ads using assets in their account.
They said their app did not measure blood pressure, heart rate, or any physiological parameters and could not perform medical measurement, diagnosis, treatment, or prevention. They said the app was a manual record-keeping tool where user’s inputted their own data, and that the app description included a disclaimer stating the app did not measure blood pressure. They said the app was not registered with the Medicines and Healthcare products Regulatory Agency (MHRA) and did not hold UKCA medical device certification because it was not a medical device.
They said neither their ads nor landing pages stated the app could measure blood pressure or blood glucose, and no efficacy or medical performance claims were made. However, they acknowledged that some visual elements could be interpreted as implying a monitoring capability, and said the specific video and banner assets referenced were automatically generated by Google’s algorithms and inadvertently created an impression of measurement functionality that did not reflect the app’s actual use.
Google said that, under its terms and conditions, advertisers were responsible for complying with its advertising policies and applicable law, including the CAP Code.
Assessment
1. Upheld
The CAP Code stated that medicinal or medical claims and indications could only be made for a medicinal product that was licensed by the MHRA, the Veterinary Medicines Regulations (VMD) or under the auspices of the European Medicines Agency (EMA), or for a medical device with the applicable conformity marking. In addition, the Medical Devices Regulations required that a medical device was registered with the MHRA before it was placed on the market in Great Britain.
The ASA consulted the MHRA ’s guidance on medical device stand-alone software including apps (including in vitro diagnostic medical devices (IVDMDs)), which stated that apps and software that simply replaced a written diary or log of symptoms that could be used when consulting with the patient’s doctor were unlikely to be considered a medical device. However, the addition of features that enhanced the data presented may bring it into the remit of the Medical Devices Regulations 2002 (MDR).
We understood that the app was intended to log blood pressure readings that had been obtained using other devices so that consumers had a record of their readings.
Ads (a) and (b) included the name “Blood Pressure Monitor App” and the same image of a digital monitor displaying “SYS mmHg” and “DIA mmHg” , which we considered consumers would likely understand to mean “systolic” and “diastolic” pressure respectively, which were the measurements taken by a blood pressure monitor. The image in the ads also included a colour-coded chart displaying red, amber and green which we considered consumers would understand to mean different blood pressure ranges, with green meaning an optimal reading, amber meaning a borderline reading and red meaning a clinically high reading.
We sought advice from the MHRA, who had concerns about the inclusion of colour-coded ranges in the image as it suggested the app enhanced the data inputted.
We considered that the chart implied the app could analyse users’ blood pressure readings to indicate whether they were normal, borderline or high, which went beyond the logging of data, and therefore constituted an enhancement of data. On that basis, we considered the app would fall within the definition of a medical device under the MDR.
We understood the app was not registered with the MHRA and did not hold the relevant conformity marking. Therefore, no medical claims could be made for it. Because the ads made such claims, we concluded that they breached the Code.
On that point, the ads breached CAP Code (Edition 12) rule 12.1 (Medicines, medical devices, health-related products and beauty products).
2. Upheld
We considered that the ads, which featured the app title “Blood Pressure Monitor App” and imagery of a digital monitor displaying systolic and diastolic readings, would likely be understood by consumers to mean that the app could measure blood pressure and was equivalent to a blood pressure monitor.
We also considered that the heart icon, reference to “PUL”, which would be likely to be understood by consumers to mean pulse rate or heart rate, and associated reading would be understood to mean that the app could also measure someone’s heart rate.
We had not seen any evidence that the app had the functionality to measure blood pressure or heart rate and we acknowledged the advertiser’s confirmation that the app only allowed users to log such data obtained using external monitors. Because the claims referred to above gave the impression that the app could measure blood pressure and heart rate, when that was not the case, we concluded that they had not been substantiated and were misleading.
On that point, the ads breached CAP Code (Edition 12) rules 3.1 (Misleading advertising) and 3.7 (Substantiation)
Action
The ads must not appear again in the form complained of. We told HealthTracker Apps t/a Blood Pressure Monitor App not to make medical claims for devices that did not hold the applicable conformity marking and were not registered with the MHRA. We also told them not to make express or implied claims that their app could monitor blood pressure or heart rate unless they held adequate evidence for such claims.
