Background
This ruling forms part of a wider piece of work on social responsibility in ads for loans offered for Christmas. The ads were 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 18 March 2026.
Ad description
A paid-for Facebook post, for Riverside Credit Union, seen in November 2025, stated, “Make Christmas magical, not stressful [Christmas Tree Emoji] Fair rates and affordable repayments straight from your Child Benefit. Apply for up to £2,000 by 19th December”. It included an image of a woman opening a box and looking surprised, with text stating, “No surprises, no hidden fees Borrow UP to £2,000 Repay through Child Benefit”. Small text at the bottom of the poster stated “Loans are subject to affordability and Terms & Conditions. An application does not guarantee a loan offer. Representative APR is 42.6%”. Text below the poster stated “Borrow from your Child benefit. Gifts, food, decorations…Christmas holidays can get expensive fast. Spread the costs with a fair and affordable Instant Loan…Apply Now”.
Issue
The ASA challenged whether the ad irresponsibly encouraged consumers to spend more than they could afford by using their child benefit payments to take out a loan to fund Christmas spending.
Response
Riverside Credit Union Ltd (RCU) stated they were a not for profit, member owned credit union that provided services for people in certain local areas in Liverpool. They explained that their lending focused on micro loans for its members who experienced long-term financial hardship, and tended to be tenants on benefits, with a high proportion being single young women with children. RCU stated that their members used the loans for items that included children’s clothing and shoes, washing machines and Christmas related spending on festive food, presents and decorations. They further stated that their members viewed borrowing and repaying via their child benefit as a sensible way to manage those needs, and said that was supported by ongoing member feedback and satisfaction surveys.
RCU said that they intended to promote a regulated and fair alternative to high cost or illegal lenders for families who were likely to borrow for Christmas in any event. They disagreed the ad encouraged people to spend more than they could afford, and said loans were subject to affordability checks and terms and conditions, with the ad stating that an application did not guarantee a loan offer. They confirmed they carried out rigorous income and expenditure assessments and budget affordability exercises before issuing loans, and that applicants who were refused were signposted to support services such as Citizens Advice and StepChange.
RCU believed the phrase “Make Christmas magical, not stressful” was subjective and that, given their due diligence, members could make a rational borrowing decision. While they maintained the ad was socially responsible, they had withdrawn it.
Assessment
Upheld
The ASA acknowledged that credit unions were often the only option of financial assistance for many consumers who would not be considered creditworthy by mainstream banks and who might otherwise turn to high-cost or illegal money lenders to obtain credit. We also understood that RCU was a not-for-profit, member owned credit union which provided loans to members, many of whom experienced long term financial hardship, and that credit unions provided services which helped their members build their credit rating. However, as with any credit provider, consumers would be required to repay what they had borrowed, with interest, and there would be consequences if repayments were not made on time. The ad promoted RCU’s instant loan, for the purpose of Christmas expenses, and we therefore focused our assessment on whether the ad presented that product responsibly.
We considered the claim “Make Christmas magical, not stressful” was likely to be understood to mean that by taking out a Christmas loan, consumers could avoid financial worry associated with Christmas and could also spend more than they would otherwise be able to afford. We considered that was reinforced by the claim “Gifts, food, decorations…Christmas holidays can get expensive fast. Spread the costs with a fair and affordable Instant Loan”.
We acknowledged RCU’s view that members found borrowing and repaying via child benefit to be a convenient way to manage their needs. We further noted that child benefit was not paid to only low-income families. However, the advertised loan was aimed at those who may not be able to obtain traditional credit due to financial circumstances, and we considered the ad’s references to repaying the loan through child benefit suggested those consumers use potentially essential benefit payments to fund non-essential Christmas spending. We considered that the overall presentation of the ad encouraged consumers, especially those in a vulnerable financial situation, to borrow for festive spending in a way that minimised the decision to take on debt and encouraged consumers to use a loan to overspend at Christmas.
We acknowledged that RCU said it had withdrawn the ad. However, for the reasons stated, we concluded that the ad encouraged consumers to take out a loan to fund Christmas spending in a way that was irresponsible and therefore breached the Code.
The ad breached CAP Code (Edition 12) rule 1.3 (Responsible advertising).
Action
The ad must not appear again the form complained of. We told Riverside Credit Union Ltd to ensure that future ads did not irresponsibly encourage excessive spending through the use of credit, particularly in relation to Christmas.
