Background
This case forms part of an ASA-initiated project group of five cases investigating ads from online personalities and companies promoting courses that purport to help people make money and expand their business.
Ad description
A paid-for Instagram post, dated 19 May 2025, for Self Made Girl Boss Ltd, a business coaching company, stated, “I bought a Digital marketing course on the 27th August and I have built a multi 6 figure business and it took me only a week to do the course, granted I became hooked! But on average it takes two weeks […] This side hustle has given me financial freedom […] all while only working 4 hours a day & making £20-30k a month […] COMMENT ‘Ready’ and I’ll send you my free beginners [sic] guide and the exact course I took to learn these skills”. The caption ended with the following “Disclaimer: These income claims are shown to show what’s possible. These results aren’t typical and my work ethic is not typical [...] it requires consistency, hard work and constant learning x”. The post further featured a video of the founder, Joanna Lopez, stating, “[…] I have made this year alone almost £300,000 […] if you are interested in doing what I do, comment READY below and I’m going to send to you my free guide and a breakdown of the course that got me making literally £20–£30,000 a month through learning high earning income skills”.
Issue
The ASA challenged whether the ad was misleading because:
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it implied the stated lifestyle and earnings were typical; and
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the claim “I’ll send you my free beginners [sic] guide and the exact course I took to learn these skills” implied that both the beginner’s guide and course, which came at a fee, were free.
Response
1. Self Made Girl Boss Ltd (SMGB) believed the ad complied with the Code as they had included the qualification “These income claims are shown to show what’s possible. These results aren’t typical and my work ethic is not typical…it requires consistency, hard work and constant learning”. That qualification made clear the figures referenced in the ad were based on personal experience and were not typical as they were dependant on various factors such as skill development, effort and consistency.
Despite that, they had removed the ad and remained open to further guidance.
2. SMGB clarified that the claim “I’ll send you my free beginners [sic] guide and the exact course I took to learn these skills” referred to two separate items: a free beginner’s guide and a paid course. They had not intended to suggest that both items would be free, and confirmed they would amend the wording to make the distinction more explicit in future ads.
Assessment
1. Upheld
The CAP Code stated that qualifications must not mislead by contradicting the claims that they qualified.
The ad claimed that the advertised course enabled SMGB to earn £20,000–£30,000 per month, and six figures in a year, while only working four hours a day, and that users who followed the course would have the opportunity to learn the same skills that enabled them to achieve those earnings.
The ASA considered that consumers were likely to interpret that to mean they could achieve the same earnings and lifestyle by following the course. We acknowledged that SMGB had placed a qualification in the ad to explain that the lifestyle and earnings displayed were not typical. However, the placement of that text was at the bottom of the ad, and consumers were likely only to see it after they had read the full caption.
We considered the qualification contradicted the impression in the body of the ad, that anyone could achieve the earnings and lifestyle if they followed the course, rather than clarifying it. We therefore concluded that the ad misleadingly implied that the stated lifestyle and earnings were typical.
On that point, the ad breached CAP Code (Edition 12) rules 3.1 (Misleading advertising), 3.9 (Qualification) and 3.11 (Exaggeration).
2. Upheld
The ad claimed that SMGB would “… send you my free beginners [sic] guide and the exact course I took to learn these skills”. We considered consumers were likely to interpret that claim to mean the beginner’s guide and course were both free. However, we understood they were separate items and while the beginner’s guide was free, the course referred to in the ad was available at a cost of £390. We acknowledged SMGB’s comments that they had not intended to suggest that both items were free and that they had agreed to amend the ad in the future. However, we considered that the distinction between the free and priced item was not clear in the ad. We therefore concluded that the claim misleadingly implied that both the course and the beginner’s guide were free.
On that point, the ad breached CAP Code (Edition 12) rule 3.1 (Misleading advertising).
Action
The ad must not appear again in the form investigated. We told Self Made Girl Boss Ltd to ensure future ads did not imply claimed lifestyle and earnings results were typical and that qualifications did not mislead by contradicting the claims that they qualified. In addition, any distinction between free items and priced items should be made clear.
