Background
This ruling forms part of a wider piece of work on social responsibility in ads for credit 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 ad for The Fragrance Shop, seen in October 2025, stated “Why wait? With our Buy Now, Pay Later option, you can get the fragrance you love, and spread your payments out over time”, The ad featured an image of a mobile phone showing The Fragrance Shop website with perfume products. Text on the image stated, “MAKE IT A STRESS-FREE CHRISTMAS WITH BUY NOW PAY LATER”. Underneath the image, it showed the logos for PayPal, Klarna and Clearpay, and text that stated “T&Cs Apply”.
Issue
The ASA challenged whether the ad was irresponsible because it encouraged consumers to spend more than they could afford by taking out credit to fund non-essential Christmas purchases.
Response
TFS Buying Ltd stated their advertising was not intended to encourage consumers to spend beyond their means. They sought customers who would spend with them regularly and so advertising that promoted consumers to get into difficult financial situations was counterproductive to their business.
They explained that the ad informed consumers of the choice to use Buy Now Pay Later (BNPL) services if they wanted to. They acknowledged that the claim “Why wait?” would be understood as encouraging consumers not to delay purchases. The ad did not however encourage consumers to increase the overall size of their spend, suggest they should buy items they did not need or that they should spend more than they could afford. Further to that it did not present BNPL as a solution to financial difficulties. They said “Why wait?” was a common phrase in the retail industry and it was used in the context of Christmas and the need to plan purchases. Further to that no other claims were used that could be seen to encourage excessive spending or trivialise borrowing.
They said the claim “MAKE IT A STRESS-FREE CHRISTMAS WITH BUY NOW PAY LATER” was intended to refer to the convenience of a deferred payment option for those who preferred to plan and manage their cashflow over the festive period, rather than stating that credit itself would remove financial stress. They said that the ad did not claim that consumers should rely on BNPL to make Christmas affordable or state that taking out credit was the only way to have a “stress-free” Christmas. They acknowledged that advertising for Christmas involved discretionary purchasing. However, they did not believe that the reference of credit in isolation, free of claims pressuring consumers to use credit to solve financial problems or increase spending, was irresponsible.
They said further, that the ad had not been designed, targeted or personalised based on indicators of financial vulnerability. In addition, the text of the ad did not exploit financial hardship or create urgency through fear of missing out due to financial circumstance.
They confirmed the BNPL facilities offered in the ad were provided by third parties at checkout and they applied their own eligibility criteria, customer checks and presented key information and terms before any agreement was entered into. Further to that customers who opted for, and were eligible for, the BNPL services were presented with the total cost and payment schedule prior to confirming any transaction. They were also able to choose alternative payment methods and were not automatically enrolled into BNPL or required to use it.
Assessment
Upheld
The ASA understood that the deferred payment option referenced in the ad, often known as BNPL, was a form of credit which was an optional payment method for purchases and allowed for payment to be delayed. While interest was generally not applied to the credit, consumers could incur late fees and any failure to keep up with payments could also affect their credit score.
The ad featured the claims “Why wait? With our Buy Now, Pay Later option, you can get the fragrance you love, and spread your payments out over time” and “MAKE IT A STRESS-FREE CHRISTMAS WITH BUY NOW PAY LATER”. We noted TFS Buying’s comments that those claims referred to planning purchases for Christmas and doing so conveniently using BNPL services. However, we considered that the claim “Why wait?”, in the context of using BNPL, was likely to be understood as encouraging purchases, of fragrances, even if an individual did not have the funds. Further, the claim “MAKE IT A STRESS-FREE CHRISTMAS…” was likely to be understood as promoting credit to take the financial worry out of Christmas.
We acknowledged Christmas was a time when people did need extra money to cover additional costs such as buying gifts, extra food to celebrate Christmas Day or travel expenses incurred by visiting family. However, we considered the highlighted claims encouraged consumers to obtain credit to spend at Christmas for fragrances, and therefore non-essentials, in an irresponsible way.
For those reasons we concluded that the ad encouraged the taking out of credit 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 in the form complained of. We told TFS Buying Ltd to ensure that future ads did not irresponsibly encourage non-essential spending through the use of credit.
