Background
This Ruling forms part of a wider piece of work on advertising for greener heating and insulation products. The ads were identified for investigation following intelligence gathering by our Active Ad Monitoring system, which uses AI to proactively survey ads in specific sectors. See also related rulings published on 6 August 2025.
On 7 April 2025, the Advertising Codes were updated to reflect the revocation and restatement of the Consumer Protection from Unfair Trading Regulations 2008 (CPRs – the legislation from which the majority of the CAP and BCAP rules on misleading advertising derived) by the Unfair Commercial Practices provisions in the Digital Markets, Competition and Consumers Act 2024 (DMCCA). On that date, the wording of a number of the rules in the Advertising Codes was changed to reflect relevant changes introduced by the DMCCA on 6 April 2025. Given the ASA’s assessment of the ad that formed the subject of this ruling was carried out before 7 April 2025 the ASA considered the ad under the wording of the rules that existed prior to 7 April 2025, and the Ruling (and references to rules within it) should therefore be read in line with this wording, available here – CAP Code and BCAP Code.
Ad description
A paid-for Meta ad for OVO Energy, an energy supplier, seen on 14 February 2025 featured a video of a spinning coin and text stated, “Save on insulation. Save on your bills” and “Switch now”. The caption stated, “Want to save on your energy bills by insulating your home? We can check if you're eligible for the Great British Insulation Scheme”.
Issue
The ASA challenged whether the ad was misleading because it omitted material information about the funding available for installing insulation products.Response
OVO Energy Ltd said the purpose of the ad was to make consumers aware of the Great British Insulation Scheme and its benefits, and to invite consumers to assess their eligibility for the scheme. The ad’s caption outlined they could assist consumers in assessing their eligibility for the Great British Insulation Scheme and the ad linked through to a landing page that offered further information.
OVO Energy said the landing page included sections headed “The Great British Insulation Scheme: what is it and who’s it for?”, “Who’s eligible for the scheme?” and included invitations for consumers to “Check if you’re eligible”. Those sections provided information on the options that might be available to consumers, together with an invitation to assess their eligibility.
OVO Energy said the “save on insulation” and “save on your bills” claims would have been read in the context of the ad as a whole, which was limited by space, and which indicated that participation in the scheme was subject to meeting the eligibility criteria.
Assessment
Not upheld
The CAP Code stated marketing communications must not mislead by omitting material information. Guidance from the Competition and Markets Authority (CMA) stated that where marketers referred to government funding anywhere in their marketing, they should make clear that access to funding was subject to a consumer meeting the eligibility criteria. The ASA had regard to the guidance in assessing whether the ad had complied with the CAP Code.
We considered consumers would interpret the claim “We can check if you're eligible for the Great British Insulation Scheme”, within the overall context of the ad, as meaning they would have to satisfy eligibility criteria in order to receive funding from the named scheme. We considered consumers would further understand that eligibility for the funding was not automatic.
The ad made clear to consumers that access to the government funding under the Great British Insulation Scheme was subject to meeting the eligibility criteria. We therefore concluded it had not omitted material information and was unlikely to mislead.
We investigated the ad under CAP Code (Edition 12) rules 3.1, 3.3 (Misleading advertising) and 3.9 (Qualification), but did not find it in breach.
Action
No further action necessary.
