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 ads for the Blood Pressure-Monitor Tracker app, a health app, seen between November 2025 and January 2026:
a. An in-app ad, seen in the Drop – The Rain Alarm app on 27 November 2025, featured an app library styled image with an icon of a pink heart with a white zig-zag line through it. Text above the icon text stated, “Record your heart rate daily Tap your finger FREE APP” next to an image of a digital fingerprint and a smaller version of the heart with the zigzag.
b. A paid-for Google ad, seen on 22 January 2026, featured a video demonstration of someone pressing their finger against a digitised white monitor device, with the words “BLOOD PRESSURE” written across the top and a light-blue screen. The device contained three labels on the right-hand side titled “SYS mmHg”, “DIA mmHg” and “PUL” and adjacent numbers on the screen changed as the finger was placed onto it, until they settled on a final number. Smaller icons and numbers appeared around the screen, including a heart symbol and a vertical bar graphic appeared on the left side of the screen, which also fluctuated once the finger was placed on the screen.
Text at the top of the image stated, “Your iPhone now supports blood pressure monitoring”. While the video played, the same app icon as ad (a) appeared together with the name of the app “Blood Pressure Monitor Tracker”.
Issue
The ASA challenged whether:
1. the medical claims in the ads breached the Code; and
2. ad (b) misleadingly implied that the app could monitor blood pressure.
Response
1. & 2. Novabeyond t/a Blood Pressure-Monitor Tracker app said the product was a consumer health app positioned as a wellness and personal health data management tool.
They said the app measured heart rate using smartphone-based PPG (photoplethysmography) technology. They said the app did not directly measure blood pressure or blood glucose; instead, users obtained those readings from external devices and either entered them manually or authorised synchronisation via Apple Health.
They said the app allowed users to track trends and organise personal health data. They said the app was intended for lifestyle tracking and information only. It was not designed to diagnose, treat, prevent, or monitor medical conditions, and included in-app notices stating the information was for reference only and did not replace professional medical advice.
They said the ads referenced in the complaint were produced by a third-party marketing company and, while the intention was to promote the app’s actual features, they recognised that the wording and visual elements, including references to blood pressure monitoring and dynamic SYS/DIA displays may have implied the app directly measured blood pressure.
They said the product had not been registered with the MHRA (Medicines and Healthcare products Regulatory Agency) because it was developed and positioned as a consumer wellness app rather than a regulated medical device, and they did not intend to market it as a medical device.
They said they had suspended advertising and would review their marketing to ensure the product was marketed as they had intended, and not as a medical device.
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 considered that consumers would understand from the claim “Record your heart rate daily Tap your finger FREE APP”, and the image of a fingerprint in ad (a), and the heart icon and PUL label, which would be likely to be understood to mean pulse rate or heart rate in the digital monitor shown in ad (b), to mean that the app could record heart rate. We noted that Novabeyond said their app used smartphone-based PPG (photoplethysmography) technology.
We sought advice from the MHRA, who confirmed that active medical devices intended to monitor vital physiological processes, including parameters related to cardiac performance, were classified as Class IIa medical devices where the nature of the parameter being monitored did not place the patient in immediate danger. They said that, because the app in this case had a medical purpose and used photoplethysmography (PPG) technology to measure heart rate, it would be performing direct monitoring of a vital physiological process and would therefore qualify as a Class IIa medical device under Rule 10 of The Medical Devices Regulations 2002 (MDR). For those reasons, and because the app was presented with a medical purpose, we understood that it would qualify as a Class IIa medical device.
We understood that the app was not registered with the MHRA, nor had we seen any evidence that it had the applicable conformity marking. Therefore, no medical claims could be made for the product. 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
Ad (b) featured the name “Blood Pressure-Monitor Tracker” alongside imagery of a pink heart with a white zig-zag line through it, which we considered was associated with heart rate and blood pressure. It also stated, “Your iPhone now supports blood pressure monitoring” and showed a graphic of a user placing their finger on a device displaying “SYS mmHg” and “DIA mmHg”. We considered consumers would likely understand these to mean “systolic” and “diastolic” pressure respectively, which were the measurements taken by a blood pressure monitor. As the user rested their finger on the phone, the numbers for each of the measurements increased before settling on final numbers, as they would with a typical blood pressure monitor. At the same time, a bar diagram on the left rose to the top which we considered implied that a reading was underway. Text at the top of the graphic stated ,“BLOOD PRESSURE”. We considered that those elements taken together gave the impression that the app could measure blood pressure using a fingertip.
However, we understood from Novabeyond that the app did not have that functionality and that it was intended as a tracker into which users could input their blood pressure readings taken on other devices.
We considered that because ad (b) gave the impression that the app could directly read someone’s blood pressure, when we understood that was not the case, we concluded that the ad was misleading.
On that point, ad (b) 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 Novabeyond Ltd t/a Blood Pressure-Tracker 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 state or imply that their product could monitor blood pressure unless they held adequate evidence to support their claims.
