Background
This ruling forms part of a wider piece of work on the availability of advertised hotel prices. 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 19 November.
Ad description
Two paid-for search ads for Travelodge Hotels Ltd, seen on 12 May 2025:
a. The first ad stated, “Travelodge Nottingham Riverside From £25”.
b. The second ad stated, “Travelodge Swansea M4 From £21”.
Issue
The ASA challenged whether the price claims in ads (a) and (b) were misleading and could be substantiated.
Response
Travelodge Hotels Ltd stated that the “from” prices displayed in the ads were automatically selected and inserted by Google, using pricing information that Travelodge provided for their Google Hotel Ads (GHA) feed. The feed was constantly updated with real-time information from Travelodge’s Property Management System to ensure it reflected live availability and pricing. When clicked on, the Google-selected links directed consumers to pages on their hotel website which displayed the specific date on which the advertised prices were available.
Travelodge stated that when consumers followed the links in both ads, they were directed to a page on the Travelodge website which showed rooms available on the date 18 May. In relation to ad (a), over 71 per cent of the available rooms at Nottingham Riverside had been available to book for £25 on that date. For ad (b), over 88 per cent of the available rooms at their Swansea M4 location could be booked for £21 on that date.
Travelodge stated that the GHA feed was a new hybrid ad model which had been recently introduced, and that multiple hotel operators used similar ad formats. They proposed requesting Google displayed the specific stay date associated with each “from” price in the ads to reduce any confusion.
Assessment
Upheld
The CAP Code stated that price claims such as “up to” and “from” must not mislead consumers by exaggerating the availability of the advertised product. CAP guidance also stated that the availability of a product at the “from” price should be spread evenly across the advertised travel period, and that marketers should make clear the specific period to which an offer related.
The ASA considered that consumers would understand the claims “Travelodge Nottingham Riverside From £25” and “Travelodge Swansea M4 From £21” to mean that a significant proportion of rooms at each hotel would be available at the advertised price. In the absence of any qualifications or date restrictions in the ads, we considered that consumers would expect to be able to find rooms at those prices across a range of dates.
We understood the ads utilised Google’s Travel Feeds in Search Ads feature, which utilised pricing and availability data provided by the advertiser to display hotel prices with paid-for search ads. For such ads, the lowest available hotel rate was selected, and the advertiser could not choose the price shown or the format in which it was displayed. However, we also understood that Travel Feeds in Search Ads was an optional feature, and it therefore remained the responsibility of the advertiser to ensure their ads complied with the Code. Consequently, we expected to see evidence, in the form of relevant pricing and availability data, to substantiate the pricing claims made, and expected that evidence to demonstrate that the advertised prices were available on multiple dates. Such data should include information about the number of rooms available at the advertised price across a range of dates, and the number available at other prices, to allow a comparison to be made.
However, we understood that the advertised prices were only available to book for a night’s stay on 18 May. Whilst a number of rooms in each hotel were available for the advertised price on that date, we considered that the availability of the advertised prices was not evenly spread across a period of time, and subsequently they were not a true reflection of the price most consumers could expect to pay. We therefore concluded that, in the absence of any information in the ads to indicate the date on which the advertised prices were available, the ads were misleading and could not be substantiated.
The ad breached CAP Code (Edition 12) rules 3.1 (Misleading advertising), 3.7 (Substantiation) and 3.17 and 3.22 (Prices).
Action
The ads must not appear again in the form complained of. We told Travelodge Hotels Ltd to ensure when using “from” price claims that, in the future, a significant proportion of rooms were available at the advertised price, and across a range of dates.
