Who: The Advertising Standards Authority (ASA), the Committee of Advertising Practice (CAP), and Glow Up LLC t/a Maxxing
Where: United Kingdom
When: 27 August 2026 and 2 September 2026
Law stated as at: 22 September 2026
What happened
CAP has published a guidance note, addressing how the UK Code of Non-broadcast Advertising and Direct and Promotional Marketing (CAP Code) applies to the advertising of AI products. The note highlights a fundamental principle that the CAP Code applies only to ads and not to the products advertised. This means that the ASA’s scrutiny is limited to how AI products are presented in advertising, rather than the AI products themselves.
CAP’s advice to marketers of AI products is to hold evidence to back up any objective claims about what the product can do, and ensure that the content is responsible.
The note flags various scenarios, drawing on ASA rulings, in which ads may exaggerate the solutions that AI products can offer or which may be seen as irresponsible or likely to cause offence.
The Maxxing ruling
In a recent example, the ASA has flagged the use of an AI tool in the context of “looksmaxxing”, a practice involving people, primarily men, trying to change their appearance through various methods to meet idealised standards. In its ruling against Maxxing, the ASA investigated two issues in relation to online ads for an AI-powered “looksmaxxing” app.
One of the ads featured a video of a teenage boy with the caption “AI scans your face, style and confidence and then builds a custom glow-up plan just for you” and on-screen text stating “NEVER look unattractive again”. The boy’s face was scanned and scored low across categories such as “Attractiveness”, “Masculinity”, “Skin” and “Jawline”. The ad continued with a to-do list including actions such as “Exfoliate your face with a gentle scrub”, followed by a photo of a man with a score of “93”. The other ad featured the same claim about AI scanning and close-up shots of a girl’s face similarly scored low, with the caption “POV: 3 months of looksmaxxing”. It then showed a photo of a different young woman with the heading “Glow-Up in 28 Days” and a to-do list, followed by a video of another woman with high scores and on-screen text stating “After Maxxing”.
The ASA found that the ads’ before-and-after footage created the impression that using the app would significantly alter a person’s appearance, reinforced by captions in the ads and the numerical scores that rated different aspects of a person’s appearance. Since no evidence was provided to substantiate that the before-and-after content was genuine, including that the same models were used, or representative of typical results, the ASA concluded that the ads were misleading.
The ASA also found that the ads were likely to exploit the potential insecurities of young people around body image, particularly since the “before” imagery appeared to depict individuals under 18 at a time when their bodies were developing and changing, which could prompt young people to be dissatisfied with their natural looks. The contrast between the before-and-after imagery, including the fact that the people in the “after” images appeared to be happier and more confident, the increased scores in both ads, the use of “masculinity” and “femininity” categories, and the suggestion that happiness depends on conforming to gender-stereotypical norms, led the ASA to conclude that the ads were irresponsible and included harmful gender stereotypes.
In its guidance note, CAP highlights that ads for such AI products could be considered as exploiting insecurities or creating pressure to conform to idealised, gendered physical standards where they claim an AI tool could give feedback relating to appearance. CAP notes that even where an ad is not for a cosmetic intervention itself, it must still be socially responsible.
Why this matters
CAP reinforces that “what the ad promises, the product should deliver”. Marketers advertising AI products should therefore hold evidence to substantiate any objective claims about what the product can do, and ensure that the content is responsible.
The Maxxing ruling is important for advertisers of AI-powered appearance or wellness tools. It shows that objective claims about what a product can do must be substantiated. Advertisers need to be mindful of the potential adverse effects that claims for such products could have on individuals, and that content targeting young people faces heightened scrutiny. More broadly, it serves as a reminder that advertisers using before-and-after imagery should be prepared to demonstrate that such content is genuine and representative of typical results achievable by consumers.
