Ad description

A paid-for Google search ad for PEL Consultancy Services, a private investigations agency, seen on 1 February 2022, stated “U.K’s Leading P.I’s.”


The complainant challenged whether the claim “U.K’s Leading P.I’s [sic]” was misleading and could be substantiated.


PEL Consultancy Services Ltd did not provide a substantive response to the ASA’s enquiries.



The ASA was concerned by PEL Consultancy Services Ltd lack of response and apparent disregard for the Code, which was a breach of CAP Code (Edition 12) rule  1.7 1.7 Any unreasonable delay in responding to the ASA's enquiries will normally be considered a breach of the Code.  (Unreasonable delay). We reminded them of their responsibility to provide a substantive response to our enquiries and told them to do so in future.

We considered that in the absence of any qualification, consumers were likely to interpret the claim “U.K’s Leading P.I’s [sic]” to mean that PEL Consultancy Services had the largest market share compared to other private investigator firms in the UK. We noted that the claim appeared in the context of a Google search, and we considered that consumers interested in obtaining the services of a private investigator would be able to identify other competitors of PEL Consultancy Services Ltd. The claim was therefore an objective, comparative claim that required substantiation with relevant documentary evidence relating to market share for themselves and their competitors in the UK market, such as comparative sales data.

In the absence of evidence showing that PEL Consultancy Services had the largest share of the private investigator services market in the UK, we concluded that the claim “U.K’s Leading P.I’s [sic]” had not been substantiated and was therefore misleading.

The ad breached CAP Code (Edition 12) rules  3.1 3.1 Marketing communications must not materially mislead or be likely to do so.  (Misleading advertising),  3.7 3.7 Before distributing or submitting a marketing communication for publication, marketers must hold documentary evidence to prove claims that consumers are likely to regard as objective and that are capable of objective substantiation. The ASA may regard claims as misleading in the absence of adequate substantiation.  (Substantiation) and  3.33 3.33 Marketing communications that include a comparison with an identifiable competitor must not mislead, or be likely to mislead, the consumer about either the advertised product or the competing product.  (Comparisons with identifiable competitors).


We referred the matter to CAP’s Compliance team. The ad must not appear again in its current form. We told PEL Consultancy Services Ltd not to claim that they were the UK’s leading PIs unless they held adequate substantiation for the claim.

CAP Code (Edition 12)

1.7     3.1     3.7     3.33    

More on