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:
Four issues were investigated, all of which were Upheld.
Ad description
a. A website for HGV Training Services Ltd, hgvt.co.uk, a heavy goods vehicle (HGV) training services provider, seen in August 2025, featured the page hgvt.co.uk/training-in-nottingham. This page included a banner at the top with text that included “SUMMER SPECIAL DISCOUNT OFFER ENDS 31ST AUGUST 2025 UP TO £500 OFF*”. The website also featured the claim, “Our experienced trainers have helped countless candidates pass their HGV/LGV license [sic] test with a pass rate of 92% using pass protection”. An “About Us” page included text that stated, “Largest provider LGV/HGV training in the UK”.
b. Pages for HGV Training Services in Glasgow, hgvt.co.uk/training-in-glasgow, Wolverhampton hgvt.co.uk/wolverhampton/ and Hampshire hgvt.co.uk/hgv-training-in-hampshire, included text that stated, “We are not only UK’s but also the best-rated HGV training provider in Glasgow”, and “our instructors and trainers” and “our facilities”.
Issue
JCoates HGV Services Ltd challenged whether the claims:
1. “up to” savings claim in ad (a) was misleading and could be substantiated, and whether the seasonal offer misleadingly implied the service would revert to the higher price once the promotion was over;
2. “Our experienced trainers have helped countless candidates pass their HGV/LGV license [sic] test with a pass rate of 92% using pass protection” in ad (a) was misleading and could be substantiated; and
3. “HGV Training Services Limited t/a HGVT is the UK’s largest provider of LGV / HGV training in the UK” in ad (a) and “We are not only UK’s but also the best-rated HGV training provider in Glasgow” in ad (b) were misleading and could be substantiated; and
4. that ad (b) falsely implied that the marketer was acting for purposes outside its trade, business, craft or profession.
Response
1. HGVT Ltd said the “up to” claim referred to the maximum achievable saving against their standard non-promotional pricing for specified course packages. The proportion of customers achieving the maximum saving exceeded 10. In addition, the claim used clear “up to” wording, which consumers generally understood to mean a maximum possible saving, not a universal one. They said the pricing structure was transparent at checkout, and all final prices were displayed before purchase. Therefore, the claim did not exaggerate availability and was not misleading.They rejected the suggestion that the seasonal promotion was misleading. They said their business operated variable promotional campaigns throughout the year, for example, “Winter Offer”, “Spring Savings”, “Summer Promotion”. While promotions may have followed one another, each promotion had a defined campaign period, a defined internal pricing structure and specific marketing assets.
The fact that promotional pricing continued in different forms did not mean an offer was not genuinely time limited. They believed it was acceptable to operate rolling campaigns without breaching the Code, provided pricing did not falsely imply a short-term reduction where no genuine higher price existed.
They confirmed that there were genuine non-promotional baseline prices, the campaign pricing was time-bound and reviewed quarterly, and internal pricing approvals demonstrated that. At no point were consumers told that prices would permanently increase immediately after expiry. They said that consumers would understand that training providers regularly ran offers and would not be materially misled. However, they said they had redesigned their promotional offerings for 2026 and would not be running ads on that basis in future and had removed promotional offers from their website.
2. HGVT said the 92% figure in the ad related specifically to candidates enrolled in their “Pass Protection” package during the period 2023–2024. They said “Pass Protection” was an optional product that allowed trainees to have up to three attempts to pass their practical training test. Their data showed that by the third attempt, 92% of trainees passed the test.
The calculation methodology was the total candidates enrolled in pass protection during that period and candidates who ultimately passed within the protection window. The resulting pass success rate was 92%. That included candidates who required more than one attempt but passed within the protection period. They said Pass Protection operated by customers paying an additional fee. If they failed their first practical test, they funded a defined number of retests and/or remedial training within stated conditions. It was not a guarantee of first-time pass and full terms were available prior to purchase.
However, they accepted that clarity was important and were willing to amend the wording of the claim.
3. HGVT said the claim, “Largest Provider LGV/HGV training in the UK” was based on the total annual enrolment volume, the national network footprint, the digital enquiry volume and booking data and market intelligence gathered over several years. They acknowledged that “largest” could be interpreted as a market-share claim. To avoid ambiguity, they were willing to amend the wording to make clear the claim was intended to relate to student enrolment.
They said the claims that they were “Best-rated in Glasgow” and “UK Best-Rated” were based on aggregated review ratings, Trustpilot rating comparisons and total review volume compared to major competitors in Glasgow. However, to remove any potential ambiguity, they would make the wording of the claim more specific.
They said they recognised that “best” implied absolute comparative superiority and would adjust the wording accordingly.
4. HGVT said they operated as a national booking and coordination provider. They managed theory booking, medical coordination, administration and customer support, plus they booked and arranged all elements of practical training, provided retests when required and ensured support of all trainees. They said their practical training was delivered via a vetted and audited network of independent training providers, under commercial partnership agreements. They also conducted quality checks, set service standards, managed the customer relationship and collected payment and paid training partners.
They said they did not receive any financial incentive from their training partners. They were funded by costs for their management services and value-added propositions. The use of phrases such as “our instructors” reflected the commercial relationship and network model. However, while they did not believe the presentation was misleading, to avoid any risk of misunderstanding, they were reviewing wording to clarify that practical training was delivered via partner schools within their national network.
Assessment
1. Upheld
Ad (a) featured the claim, “SUMMER SPECIAL DISCOUNT OFFER ENDS 31ST AUGUST 2025 UP TO £500 OFF*”. The ASA acknowledged that HGVT said the “up to” claim referred to the maximum achievable saving against their standard non-promotional pricing for specified course packages, and that the proportion of customers achieving the maximum saving exceeded the 10% rule-of-thumb. However, HGVT did not provide documentary evidence to demonstrate how the saving was calculated, what the genuine non-promotional baseline prices were or the proportion of customers who achieved the maximum £500 saving. We therefore considered the “up to £500 off” saving claim was misleading.
We also considered the claim “OFFER ENDS 31ST AUGUST 2025” was likely to give consumers the impression the promotional price advantage was only available for a limited period and that prices would revert to the non-promotional rate once the offer ended. We understood HGVT said they ran variable campaigns throughout the year and that each campaign had a defined period and pricing structure, and that they had genuine non-promotional baseline prices. We welcomed HGVT’s willingness to make changes to their advertising. However, because they did not provide documentary evidence to demonstrate that the higher, non-promotional prices applied for a meaningful period, or to show how the closing date related to the availability of the stated saving, we considered consumers were likely to be misled about the nature of the promotion and the urgency implied by the closing date.
On that point, ad (a) breached CAP Code (Edition 12) rules 3.1 (Misleading advertising), 3.7 (Substantiation) and 3.22 (Prices).
2. Upheld
Ad (a) also featured the claim, “Our experienced trainers have helped countless candidates pass their HGV/LGV license [sic] test with a pass rate of 92% using pass protection”. We understood the 92% figure was intended to relate specifically to candidates enrolled in their “Pass Protection” package in 2023–2024, and reflected candidates who ultimately passed within the protection window, including those who passed after more than one attempt.
However, HGVT did not provide documentary evidence to substantiate the 92% pass rate. We also noted the ad did not make clear how pass protection worked. For example, it did not clarify that candidates had up to three additional retests within defined conditions, or that the 92% pass rate for those taking up to three tests using pass protection was based on previous years. Because the basis of the claim was not clear, and because we had not seen evidence to substantiate it, we concluded that it was misleading.
On that point, ad (a) breached CAP Code (Edition 12) rules 3.1 and 3.3 (Misleading advertising) and 3.7 (Substantiation).
3. Upheld
Ad (a) stated “HGV Training Services Limited t/a HGVT is the UK’s largest provider of LGV / HGV training in the UK” and ad (b) stated “We are not only UK’s but also the best-rated HGV training provider in Glasgow”. We acknowledged that HGVT said the “largest” claim was based on factors such as enrolment volume, network footprint and market intelligence, and that the “best-rated” claim was based on aggregated review ratings, including Trustpilot comparisons.
However, HGVT did not provide documentary evidence to substantiate either claim. We considered consumers would likely understand the “largest” and “best-rated” claims as objective, absolute comparative claims. We therefore considered consumers would expect the claims to be supported by robust, verifiable and representative data, including clear comparisons against relevant competitors. Because we had not seen that evidence, we concluded the claims had not been substantiated and were misleading.
On that point, ad (a) breached CAP Code (Edition 12) rules 3.1 (Misleading advertising), 3.7 (Substantiation), 3.32 and 3.34 (Comparisons with identifiable competitors).
4. Upheld
Ad (b) referred to “our instructors and trainers” and “our facilities”. We understood that HGVT operated as a national booking and coordination provider and that practical training was delivered through a network of independent training providers, with HGVT managing administration, support and customer relations.
However, we considered the claims were likely to give consumers the impression that HGVT directly provided the training using its own instructors and facilities, whereas instead it obtained a proportion of its income from its management services, and that the nature of its commercial role was not made clear from the context. We concluded that ad (b) misleadingly implied that HGVT were acting for purposes outside their business and therefore breached the Code.
On that point, ad (b) 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 HGVT Ltd not to make “up to” claims unless a significant proportion of items were available at the advertised maximum discount, to ensure that seasonal offers and pass rate claims were not misleading, and that all such claims could be substantiated. We also told them to ensure that they did not falsely imply they were acting for purposes outside their business.
CAP Code (Edition 12)
2.3 3.1 3.22 3.3 3.32 3.34 3.7
