Background
On 7 April 2025, the Advertising Codes were updated to reflect the revocation and restatement of the Consumer Protection from Unfair Trading Regulations 2008 (CPRs – the legislation from which the majority of the CAP and BCAP rules on misleading advertising derived) by the Unfair Commercial Practices provisions in the Digital Markets, Competition and Consumers Act 2024 (DMCCA). On that date, the wording of a number of the rules in the Advertising Codes was changed to reflect relevant changes introduced by the DMCCA on 6 April 2025. Given that ad was published before 7 April 2025, the ASA considered complaints about that ad under the wording of the rules that existed prior to 7 April 2025. The Ruling (and references to rules within it), in relation to that ad, should therefore be read in line with this wording, available here – BCAP Code and CAP Code.
Ad description
Six ads for Vodafone:
a. A TV ad, seen in July 2025, opened with a man carrying a large bag and who was talking to a friend on his mobile phone as he got off a train. He said, “Guess who’s back for summer baby?” He then said, “Are you not coming?” He was then called out to by another friend who was standing in front of a car that had the number plate “TNN 1984”, and was shown being greeted by his friend who said, “Welcome back baby!” Another couple were then seen enjoying drinks in their garden as they laughed together over something they were watching on their phone. In another scene, a group of friends were seen in the outside area of a pub talking about the football. One was looking at his phone and a friend said, “What’s he looking at?” At that point, on-screen text stated, “The Nation’s Network: Vodafone UK, supporting the nation since 1984 and has 99% of the UK population coverage. Verification: Vodafone.co.uk/network”. The ad then showed three women who appeared to be inside a music festival tent among a crowd dancing. One of them was holding up her phone and they were screaming with excitement. The ad showed the screen which showed someone holding a newborn baby. A voiceover and on-screen text stated, “Keeping you and your friends connected this summer. Vodafone. The Nation’s Network.” On-screen text below “The Nation’s Network” stated “Supporting the nation since 1984”.
b. A paid-for YouTube ad, seen in July 2025, opened with a voiceover and on-screen text stating “Connecting friends this summer on Vodafone. The Nation’s Network.” It featured the same scenarios and on-screen text as ad (a). An end-frame featured text stating “The Nation’s Network. Est. 1984. Switch to Vodafone” and a final voiceover stated, “Switch to Vodafone today”.
c. A paid-for Meta ad, seen in July 2025, featured a video which was filmed from the viewpoint of someone off-camera. It opened with them shaking hands with a man at a festival. The man was wearing several wristbands including a red one. A moving graphic in the centre of the screen stated “POV: Enjoying Glastonbury on the Nation’s Network”. Smaller text underneath stated “Est. 1984”. The ad then showed short scenes of the person’s hands as they used their mobile phone whilst exploring Glastonbury. In one scene their hands were shown DJing. In another their hands were shown driving dodgems. In another they were taking a photo on their phone of two other people. In another the screen of their mobile phone showed a map. In another they were inside a red branded tent. In another their hand was seen reaching out to accept a drink from a cocktails van. In another they were shown filming a table football match on their phone. In the final scene they were shown in the red branded tent handing over what appeared to be a power bank to a person wearing a Vodafone branded t-shirt and taking a new one. Small on-screen text which appeared part-way through stated “The Nation’s Network: Vodafone UK is [sic] nation’s most valuable UK telecoms provider & most valuable UK brand overall verified by Kantar BrandZ Most Valuable UK Brands Report 2024 and support the nation since 1984 through to 2025’s major summer events & beyond. Verification of claims: Vodafone.co.uk/network”.
d. A paid-for Meta ad, seen in July 2025, featured a caption stating “Connecting friends this summer on Vodafone with 99% coverage across the UK. The Nation’s Network. Roman meets pal, Jack Draper, on Vodafone a Friend”. A video showed Roman Kemp and tennis player Jack Draper, in the stands of the centre court at Wimbledon. Roman said to Jack, “Are you ready to phone a friend on the Nation’s Network?” Overlaid text stated “The Nation’s Network Est. 1984 Vodafone a friend”. Small on-screen text stated “The Nation’s Network: Vodafone UK, supporting the nation since 1984: Vodafone.co.uk/network”.The ad then cut to a split screen showing Jack’s brother answering questions about Jack and Jack’s own answer. After answering five questions correctly, Roman told him “You’ve won those tickets to Wimbledon for your local community team.” An end-frame stated “Connecting friends this summer. The Nation’s Network” and the same small on-screen text as before appeared again.
e. A poster, seen on the side of a bus in February and March 2025, featured headline text stating “This is London’s Best Network”. Smaller text in the lower left-hand corner of the ad stated “The Nation’s Network, supporting you since 1984”. Small print directly underneath that text stated “Nation’s Network: Vodafone UK is [sic] nation’s most valuable UK telecoms provider & most valuable brand overall, verified by Kantar BrandZ Most Valuable UK Brands Report 2024 and supports the nation since 1984 through to 2024’s major summer events & beyond […]”.
f. A poster, seen on a bus stop in May 2025, featured an image of someone’s hand holding a mobile phone which had an image of a London cityscape. A headline stated “This is London’s Best Network. Smaller text at the bottom of the poster stated “The Nation’s Network, supporting you since 1984”. Small print directly underneath that text stated “The Nation’s Network: Vodafone – nation’s most valuable brand, verified by Kantar BrandZ Most Valuable UK Brands Report 2024, and supporting the nation since 1984 through to 2025’s major summer events. See full verification of the substantiation: Vodafone.co.uk/network […]”.
Issue
EE, who believed the claim “The Nation’s Network” was an implied comparative superiority claim, challenged whether the ads were misleading.
Response
Vodafone Ltd t/a Vodafone said the claim “The Nation’s Network” was not an implied comparative superiority claim; it was a corporate positioning statement or strap line that was not capable of objective substantiation. They said it was a brand platform that reflected Vodafone’s legacy, cultural sponsorships and emphasised their role and reach. They said it was consistently framed with heritage qualifiers such as “Est. 1984” and “Supporting the nation since 1984” and was never used in conjunction with unsubstantiated technical performance metrics. They believed the fact that the claim did not include an adjective supported their position that it was not a superiority claim against their competitors. They maintained that “The Nation’s Network” could only be construed as an objective claim when it was used alongside an attribute of their service, such as network penetration, reliability or performance. In the absence of such attributes, it was simply a corporate positioning statement that was not capable of objective substantiation. They pointed out that no consumers had complained about the use of “The Nation’s Network”, which they believed supported that position and suggested that consumers were unlikely to view the phrase as an objective claim capable of substantiation, let alone a claim that was comparative or superlative, and they were also unlikely to view it as being materially misleading.
They referred to a 2024 Most Valuable Brands in the UK Report published by a third-party market research company in which they were recognised as the most valuable UK telecoms provider for the eighth consecutive year, as well as the most valuable UK brand overall in 2024. They said the recognition resulted from a rigorous and comprehensive study involving 4.3 million customer interviews across 54 markets, evaluating 21,000 brands globally, which combined financial data with consumer perception. They said that whilst that study’s finding was not intended to support a comparative superiority claim, it did reinforce Vodafone’s legacy and connection with the British public, i.e., the nation. It also reflected the trust, familiarity and cultural relevance that Vodafone considered it had built over the decades, either through innovation or consistent brand presence. They said consumers would naturally associate Vodafone with the phrase “The Nation’s Network” due to that legacy, and through Vodafone’s brand recognition and national identity. The report was therefore contextual evidence of their heritage and brand standing, rather than substantiation for a comparative superiority claim against their competitors.
They said Vodafone had invested heavily in the sponsorship of various summer events with large cultural significance in the UK, which showed Vodafone’s commitment to national connection and community engagement. As the Official Connectivity Partner of both Wimbledon and Glastonbury they provided free phone charging and a new festival app at Glastonbury. Those initiatives were intended to enable moments of connection that mattered to people, rather than promoting network features. Their “Connecting friends this summer” advertising campaign had been built around those shared experiences, reinforcing their role in supporting the nation through cultural touchpoints rather than technical metrics. They said their enduring presence at iconic British events strengthened their brand heritage and helped to explain why the public may naturally associate Vodafone with the phrase “The Nation’s Network”. That phrase reflected their legacy of connecting people, not just through infrastructure but also through shared experiences.
They pointed to a previous ruling of the ASA (the April 2025 Ruling) in relation to an earlier TV ad using the claim “The Nation’s Network” which had supported that interpretation (the Christmas ad) and had not been found to imply superiority against competitors or to be misleading. They understood that the April 2025 Ruling permitted the use of “The Nation’s Network” when it was clearly conceptualised as a heritage-based message. They said that while they acknowledged the ASA’s recognition of Vodafone’s heritage as a foundational element of “The Nation’s Network”, they believed their right to use the claim was not derived from heritage alone. By reducing the strap line to heritage only, they said the ASA was overlooking the broader context in which the strap line operated, namely their continued support for national infrastructure, emergency services and cultural events. They said that duality – heritage and ongoing operational role in UK connectivity – was central to the brand narrative and meaning behind the claim.
They said all the ads were framed within that context of heritage and support for national infrastructure, emergency services and cultural events, supported by qualifying text such as “Est. 1984” and “Supporting the nation since 1984” and were not juxtaposed with performance metrics unless appropriately substantiated. They said their use of “Supporting the nation since 1984” was not a passive reference to the past. It was an active statement of their ongoing role in UK connectivity through network coverage, cultural sponsorships and enabling moments of connection at major national events. They believed ads (a)–(f) ads made that explicit: the cues were not presented in isolation but were paired with contemporary depictions of national events and everyday connectivity to demonstrate continuity between their heritage and current operations. They said in three of the six ads they included the small print “through to 2025’s major summer events and beyond”, which clearly linked the substantiation to their current operations and sponsorship of events.
They said that ads (a) and (b), which had been approved by Clearcast and had not generated any complaints from viewers, depicted scenes of friends reuniting at train stations, an older couple sharing a humorous moment in their garden, and a group of friends at a festival connecting with a new mum at home. Those vignettes had been chosen to reflect the events Vodafone sponsored, which were deeply embedded in the UK’s national identity. They were rooted in brand storytelling, not comparative advertising and reflected Vodafone’s legacy of connecting people across the UK since 1984, supported by their cultural sponsorships and brand recognition. They believed the use of “The Nation’s Network” in those ads was entirely consistent with the Christmas ad and did not mislead or imply superiority over competitors. They believed there were sufficient contextual cues in ads (a) and (b) to anchor “The Nation’s Network” claim in their heritage and current operations. In both ads the car number plate was “TNN 1984”, the man getting off the train was carrying a rucksack and tent because the two friends were going to a festival and a later scene showed a group of friends dancing in a festival tent. Those depictions directly related to Vodafone’s sponsorship presence at various summer festivals throughout the UK including, for example, Glastonbury, Boardmasters and Kendal Calling. In ad (a) “Supporting the nation since 1984” appeared immediately and prominently underneath “The Nation’s Network”. That was coupled with the voiceover, “Keeping you and your friends connected this summer”, which they said was a direct, unambiguous cue to their heritage and ongoing role in national connectivity and signalled continuity and legacy rather than a one-off moment.
The ads included the same body copy as the Christmas ad: “Supporting the nation since 1984”. They pointed out that the phrase was not presented alongside network performance metrics and believed it did not imply technical superiority. They said they had emphasised their positioning of heritage in ads (a) and (b), compared to the Christmas ad, by including the statement “Supporting the nation since 1984” in the end frame, directly underneath “The Nation’s Network”, giving it more prominence.
They acknowledged that the small print included a reference to “99% UK population coverage”. However, that was intended solely to illustrate Vodafone’s reach in connecting people, and not to suggest that their coverage was superior to that of any other providers. They acknowledged that 99% population coverage was industry standard. They said they had now proactively removed that reference from their advertising.
They acknowledged that ad (b), the YouTube ad, included a voiceover which stated, “Switch to us today”. They said that call to action was standard in consumer advertising on YouTube and did not reference or promote any specific network features which might have implied technical superiority.
Vodafone said that ad (c) opened with the moving graphic in the centre of the screen “POV Enjoying Glastonbury on The Nation’s Network”, which included the text “Est. 1984” directly underneath “on The Nation’s Network” as an explicit cue that directly linked their present-day role at Glastonbury to their longstanding history in the UK. It had small print which stated “The Nation’s Network: Vodafone UK is the nation’s most valuable UK telecoms provider & most valuable UK brand overall, verified by […] Most Valuable UK Brands Report 2024, and support the nation since 1984 through to 2025’s major summer events and beyond. Verification: Vodafone.co.uk/network.” That directly linked their heritage to ongoing support for national events and made clear that their role at Glastonbury was part of a continuous legacy of national support. Every reference to “The Nation’s Network” in the ad was accompanied by “Est. 1984”. They said visuals of Glastonbury, one of the UK’s most iconic cultural events, reinforced their active current role in national connectivity. They believed the ad contained clear visual cues that made it apparent that Vodafone was the official connectivity partner at the event. They said the man shaking hands at the start of the ad was wearing a Vodafone retreat red wristband. They said further scenes featured the mobile phone using the Vodafone Glastonbury app; in one, the person was seen reviewing their step count in the app, in two other scenes the person was seen using the app to locate on a map the area they were looking for. Another scene was filmed inside Vodafone’s connect and charge tent at Glastonbury which had Vodafone’s red branding everywhere in the background. The final scene showed the person, carrying a Vodafone branded power bank, walking into the Vodafone tent at Glastonbury. They said Vodafone staff were seen behind the counter and “Glastonbury on the Nation’s Network” was displayed behind them. The person was seen swapping the empty power bank for a full one (which was a service offered by Vodafone at Glastonbury). They said it was obvious Vodafone were the official connectivity partner of the event because they would not have been able to host and advertise the festival tent shown in the ad – that would be considered ambush marketing.
They believed that for the average consumer, the combination of (a) “Est. 1984”; (b) explicit references to national support, including the reference in the small print “[…] through to 2025’s major summer events & beyond […]”; and (c) the context of a major UK event, amounted to a clear, non-comparative statement of Vodafone’s longstanding and ongoing contribution to UK connectivity. They therefore believed the ad clearly contextualised the claim as relating to their heritage and their current role in national connectivity.
They said that ad (d) featured a snippet of an interview at Wimbledon between their brand ambassador and former ambassador. The interview centred around the theme “Vodafone a friend”, highlighting a personal connection between the interviewee and someone they cared about. The ad was designed to evoke warmth, familiarity and emotional resonance. It included the small print “The Nation’s Network: Vodafone UK, supporting the nation since 1984. Verify: Vodafone.co.uk/network and “Est 1984” appeared directly underneath “The Nation’s Nework”.
They said ad (d) contained clear heritage cues. “Supporting the nation since 1984” was intentionally placed directly beneath the strap line, in small print, and was used consistently to cue their long-standing national presence. The Wimbledon visuals – one of the UK’s premier cultural and sporting events – further reinforced their ongoing role in national connectivity. They also believed it was apparent that Vodafone sponsored the event from the fact that Jack Draper was seen winning tickets for his local community team in the ad, as those tickets were provided by Vodafone as the official connectivity partner of Wimbledon. Furthermore, no other operator would have been able to film at that location, with that tennis star (Vodafone’s brand ambassador) and offer Wimbledon tickets – it would be considered ambush marketing. They believed ad (d) sufficiently clearly contextualised “The Nation’s Network” as relating to their heritage and their current role in national connectivity in accordance with the April 2025 Ruling and was not misleading. They said the ad did not reference or promote any network features, nor did it imply comparative superiority. As above, they said they had proactively removed the reference to “99% UK population coverage” from the ad.
In relation to ads (e) and (f), they explained that they were part of a short, geographically targeted campaign focused exclusively on London. The headline claim in the ads, “London’s Best Network”, was visually distinct and separate from the text which stated “The Nation’s Network, supporting you since 1984” with the same accompanying small print as in ad (c), which was positioned directly underneath and included the text “and supporting the nation since 1984 through to 2025’s major summer events”. They said “London’s Best Network” was a separate, geographically specific, technically substantiated statement, whereas “The Nation’s Network” was a heritage- and operations-based brand positioning statement. They said it was inaccurate and unfair to conflate the two.
In relation to ad (a) only, Clearcast said they had worked closely with Vodafone from an early stage to ensure that no comparative superiority claims were made in the ad. They said the line “The Nation’s Network” was qualified in superimposed text which made clear what Vodafone meant by it: “Supporting the nation since 1984” and with “99% of the UK Population coverage”. They were aware that the superimposed legal text was not on screen at the same time as the “The Nation’s Network” claim. However, they believed that the legal text was self-contained as it already contained the claim “The Nation’s Network” (followed by a colon), so they believed it was inherently clear to the viewer what the legal text was referring to and therefore would make the link with “The Nation’s Network” on-screen text which appeared later in the ad.
They did not believe that made any suggestion other than that Vodafone had been in the UK delivering a network since 1984 and today covered 99% of the people within the UK. They believed that viewers would understand that to be justifiable for a claim of being the Nation’s Network and that it was clearly explained in the ad. Furthermore, “supporting the nation since 1984” was repeated at the end of the ad to leave viewers in no doubt that that was what Vodafone meant when they said “The Nation’s Network”.
They said the ad did not contain any direct statements or indirect implications that suggested Vodafone was claiming to be “better” or “more” than any competitors. The ad did not say, for example, “The Nation’s Number 1 Network” or “The Nation’s Best Network”; the ad simply said, “The Nation’s Network”, with no superlatives.
They also referred to the April 2025 Ruling. They believed the claim in the current TV ad had been presented in a similar context to the Christmas ad and therefore was not making an objective comparative claim against Vodafone’s competitors. In particular, the current ad focused on various slices of summer life, with people using Vodafone’s network in ordinary scenarios. The ad did not contain any scenes which suggested Vodafone was capable of delivering a network of performance above and beyond what would be expected from any network. Also, there were no comparative claims about the network made in the visuals or the audio. They therefore believed it was clear that Vodafone were claiming themselves to be a network for everyday people and had been since 1984.
Assessment
Upheld
The ASA acknowledged Vodafone and Clearcast’s comments in relation to the April 2025 Ruling, which had concluded that the claim “The Nation’s Network” within the context of the visuals and scenario presented across various scenes of mobile technology being used in different eras, and the text “Connecting you at Christmas for 40 years” and “supporting the nation since 1984” would be understood to be in relation to Vodafone’s history and heritage.
Whilst the principles set out in that Ruling applied, we considered the creative content of the Christmas ad was fundamentally different to the creative content of ads (a)–(f). That ad had featured scenes of individuals using mobile technology from different eras and included text which stated “Connecting you at Christmas for 40 years” that were not present in ads (a)–(f).
We understood that Vodafone intended the claim “The Nation’s Network” to be a subjective expression of their legacy, history and heritage as a UK telecoms brand as well as their present-day role supporting the nation through their sponsorship of and presence at major British cultural events, their support for the emergency services and their role in enabling people to connect across the nation.
Ads (a) and (b) had the theme “Connecting friends this summer” and featured scenes of people re-uniting with, and enjoying socialising with, their friends in different scenarios. We considered the focus of the ad was on Vodafone’s current operations as a network provider that connected people and there was nothing in the visuals and imagery in those scenes that obviously reflected Vodafone’s history or heritage as a UK telecoms brand or which highlighted their role in providing sponsorship of major British cultural events or support to the emergency services. We considered the visual cues highlighted by Vodafone, in particular, the “TNN 1984” car number plate, the fact that the man at the train station was carrying a large bag or tent, and the scene featuring the friends dancing at a festival were insufficient to clearly communicate that to viewers.
The on-screen text which stated “The Nation’s Network: Vodafone UK, supporting the nation since 1984 and has 99% of the UK population coverage. Verification: Vodafone.co.uk/network” appeared part-way through the ads and not at the time “The Nation’s Network” claim was presented on-screen or in the voice-over. Nevertheless, we considered that it was not sufficient, either through its content or its prominence, to make sufficiently clear to viewers that “The Nation’s Network” was a subjective expression reflecting Vodafone’s history and heritage, and its ongoing operational role supporting the nation, for example by sponsoring major cultural events and supporting the emergency services.
We acknowledged that the ads featured smaller text under “The Nation’s Network” in the end-frame which stated “Supporting the nation since 1984” in ad (a) and “Est. 1984” in ad (b). We noted “The Nation’s Network” was also stated in the voice-over and had significantly more prominence than the statements underneath. Furthermore, while we acknowledged those statements related to the year in which Vodafone was established and the length of time it had been trading, we considered they were insufficient to clearly communicate to viewers that “The Nation’s Network” was a subjective expression of Vodafone’s heritage.
Ad (c) was a video of someone exploring Glastonbury whilst using their phone and had the headline “POV Enjoying Glastonbury on The Nation’s Network”, with smaller text underneath stating “Est. 1984”. The ad featured fleeting scenes from around the Glastonbury site filmed from the perspective of a person carrying and using a mobile phone. In one brief scene they were on the dodgems, in another they were DJing, and in another they were filming a table football match. In one scene they were in a red and white coloured tent and swapped what appeared to be a mobile phone power bank with someone wearing a Vodafone-branded t-shirt. Some writing on the wall behind, which was partially obscured and in reflective silver which made it difficult to read, stated “The Nation’s Network”. We did not consider it would have been clear to consumers that the Glastonbury app was being used in the ad. Although we acknowledged that no other brand (except the official connectivity partner) would have had have such a presence at a festival, we did not consider consumers would understand from the red tent in the ad that Vodafone was the official connectivity partner of the event, as Vodafone had suggested was the case. We considered that although the ad contained some visual cues that Vodafone had a presence at Glastonbury, such as Vodafone’s brand colour (red) being featured throughout, those cues were subtle, and the ad did not make clear that Vodafone was the official connectivity partner of the event. We therefore considered the ad did not provide sufficient contextualisation for viewers to understand “The Nation’s Network” to be a subjective expression reflecting Vodafone’s ongoing role in UK connectivity for example by sponsoring major British cultural events.
We also considered there was nothing in the visuals or audio in the video that reflected Vodafone’s history or heritage as a UK telecoms brand. As with ad (b), we did not consider that “Est 1984” provided sufficient contextual information for consumers to clearly understand that “The Nation’s Network” was, in part, a heritage-based claim.
The ad contained small on-screen text stating “The Nation’s Network: Vodafone UK is the nation’s most valuable UK telecoms provider & most valuable UK brand overall, verified by […] Most Valuable UK Brands Report 2024, and support the nation since 1984 through to 2025’s major summer events and beyond. Verification: Vodafone.co.uk/network.” We considered that although that text made reference to the length of time Vodafone had been operating and referred to “2025’s major summer events”, it was not sufficient either through its content or its prominence to clearly contextualise “The Nation’s Network” as a subjective expression of Vodafone’s heritage and ongoing role in UK connectivity, for example by sponsoring major British cultural events.
Ad (d) featured a video of the tennis player Jack Draper being interviewed by Roman Kemp with Wimbledon as the backdrop which had a caption stating “Connecting friends this summer on Vodafone with 99% coverage across the UK. The Nation’s Network. Roman meets pal, Jack Draper, on Vodafone a Friend”. Overlaid text on the video also stated “The Nation’s Network. Vodafone a friend” and “Connecting friends this summer. The Nation’s Network”. We considered that there was nothing in the visuals or audio in the video that reflected Vodafone’s history or heritage as a UK telecoms brand except the reference in the small print to “Supporting the nation since 1984”. However, as above, we considered that reference alone did not provide sufficient contextual information for consumers to clearly understand that “The Nation’s Network” was a heritage-based claim. Furthermore, although the video had Wimbledon as its backdrop and text in the caption stated “Connecting friends this summer”, there was no reference in the ad to Vodafone being the official connectivity partner of Wimbledon 2025 or to explain its role or presence at the event. We did not consider that the Wimbledon backdrop, the inclusion of Jack Draper or the winning of Wimbledon tickets as portrayed in the ad were sufficient to convey that Vodafone was the official connectivity partner. We therefore considered the ad did not provide sufficiently clear contextualisation for consumers to understand that “The Nation’s Network” was a subjective expression of Vodafone’s ongoing role in supporting major UK cultural and sporting events. We also considered that the reference to “99% coverage across the UK” could have led some consumers to understand Vodafone was “The Nation’s Network” because it had a greater coverage in the UK than other network providers, which we understood was not the case due to it being industry standard.
Ads (e) and (f) were static ads that had a headline “London’s Best Network”, which we understood was based on the objective benchmarking of mobile networks performance in Greater London, but we had not assessed the validity of that claim as part of the investigation. Smaller text below stated “The Nation’s Network, supporting you since 1984”, together with small print which included the text “and supporting the nation since 1984 through to 2025’s major summer events” and reference to the Most Valuable UK Brands Report 2024. The ads did not contain any imagery relating to Vodafone’s history or heritage or its ongoing role in supporting the nation through, for example, the sponsorship of major cultural events or through the emergency services. For the reasons set out above, we did not consider the text “supporting you since 1984” or “and supporting the nation since 1984 through to 2025’s major summer events” to be sufficient to contextualise “The Nation’s Network” as a heritage-based claim or a subjective expression of Vodafone’s role in supporting the nation at cultural events.
We therefore considered that the ads did not include a clear contextual basis for the claim “The Nation’s Network”.
In the absence of a clear explanation for the basis of the claim in the ads, we considered that there were several possible consumer interpretations for it. For example, we considered that some consumers might understand that Vodafone were expressing their subjective view that they were “the Nation’s Network” because they were a UK-based network, which provided services to the UK since 1984. However, we considered at least a significant minority of consumers were likely to interpret the claim as being an objective comparative claim against the UK’s other network providers. For example, we noted the ads did not state Vodafone was “one of the nation’s networks”, or “a network serving the nation”, which would be unlikely to be considered as comparative, depending on the context in which they appeared.
One such interpretation, that we considered that a significant minority of consumers were likely to hold, was that Vodafone was more popular than, or had more customers than, other networks that also provided telecoms services to UK consumers. We considered that the scenarios presented in ads (a) and (b), of groups of people enjoying leisure activities, added to that impression.
We also considered that some consumers were likely to view the claim, particularly in the context of the ads which referred to “99% population coverage”, “the nation’s most valuable UK telecoms provider” and “London’s Best Network”, to mean that Vodafone was the nation’s network because it was more reliable or offered better connectivity or coverage than other network providers.
The CAP and BCAP Codes required that comparisons with identifiable competitors must objectively compare one or more material, relevant, verifiable and representative features of those products. As such, we expected the ad to objectively compare one or more verifiable feature. Because we considered that was likely to be understood by consumers in a range of ways (including as a comparison against all other UK networks, for example that Vodafone was the most popular network in the UK or had the most customers), we considered the ads failed to objectively compare one or more material, relevant, verifiable and representative feature and concluded that the claim “The Nation’s Network”, as it appeared in the ads, breached the Code.
Ad (a) breached BCAP Code rule 3.36 (Comparisons with identifiable competitors).
Ads (b), (c), (d) and (f) breached CAP Code (Edition 12) rule 3.34 (Comparisons with identifiable competitors).
Ad (e) breached CAP Code (Edition 12) rule 3.35 (Comparisons with identifiable competitors) [rule as worded pre-7 April 2025].
Action
Ads (a)–(f) must not appear again in the form complained of. We told Vodafone Ltd to ensure they objectively compared one or more material, relevant, verifiable and representative feature if making an implied comparative claim in future.
