Who: The Advertising Standards Authority (ASA), Abellio ScotRail Ltd t/a ScotRail (ScotRail), GA Trains Limited t/a Greater Anglia (Greater Anglia)
Where: United Kingdom
When: 24 December 2025
Law stated as at: 6 February 2026
What happened
The ASA has published a series of rulings as part of a wider investigation into online advertising in the rail industry concerning “lowest” or “cheapest” price claims. The cases involved train operating companies making unsubstantiated claims about offering the “lowest” ticket prices, and the ASA upheld complaints in relation to both.
ScotRail’s website featured claims including “Get cheapest tickets”, “Book direct for our best price” and “Unbeatable on price”. ScotRail argued that its journey planner provided search results indicating the cheapest available fares and whether split-ticketing was available for the selected journey. It contended that the claim “Book direct for our best price” referred to consumers “always” paying the lowest price ScotRail offered, noting that it applied no additional booking fees to standard fares, unlike some third-party retailers. Regarding the claim “Unbeatable on price”, ScotRail stated that its prices “could not be beaten” because it charged no booking fees, and that this was further supported by a price promise to reimburse consumers if a genuine lower like-for-like Seasons or Anytime fare was found elsewhere.
Greater Anglia’s website homepage featured the claim “Book direct for lowest prices & no fees”. Greater Anglia stated that the purpose of the claim was to inform consumers that the company offered the lowest ticket on any given day, and that the overall cost could be cheaper than other retailers because it charged no booking fees. After reviewing the complaint, Greater Anglia acknowledged that its messaging was confusing, noting that while split-ticketing options through third-party retailers could slightly reduce fares on some journeys, those same fares could be achieved on its website if customers purchased tickets separately, though not all consumers would be aware of this possibility.
Both operators were subject to the National Rail Ticketing and Settlement Agreement (TSA), which sets out the framework within which train operating companies can set rail fares. Operators are not permitted to create or sell their own fares outside of the TSA framework.
The ASA considered that most consumers were unlikely to have knowledge of the rules governing how ticket prices were set, and were likely to understand that ScotRail and Greater Anglia were able to offer competitively priced tickets by monitoring their fares against those of their competitors, including third-party retailers. The ASA therefore expected the operators to hold evidence to substantiate their claims.
The ASA considered that consumers would understand claims such as “Get cheapest tickets”, “Unbeatable on price” and “Book direct for lowest prices” to mean that they could purchase tickets at the lowest available price for their chosen journey, and that they implied that it was unnecessary to look for cheaper tickets elsewhere. The ASA determined that these were “lowest price” (or “best price”) claims that had to be backed up by suitable evidence showing the operators would always beat, and not merely match, competitors’ prices.
The ASA acknowledged that ScotRail and Greater Anglia did not charge a booking fee. However, it highlighted that some third-party retailers also did not charge booking fees, meaning the operators could not beat competitors’ prices.
Although ScotRail’s website indicated whether split-ticketing was available, there was no evidence that it would beat split-ticketing prices offered by third parties. ScotRail’s price promise only offered to refund the difference for certain ticket types. The complainant had been able to find cheaper tickets using third-party services.
The ASA acknowledged that cheaper fares found through split-ticketing providers could be achieved on Greater Anglia’s website if consumers purchased tickets separately. However, consumers would only be able to do this if they were aware of the possibility, which Greater Anglia acknowledged not all consumers would be. The ASA, therefore, concluded that the claim “Book direct for lowest prices” discouraged consumers from searching elsewhere for cheaper tickets. Greater Anglia also provided no evidence that, through purchasing tickets separately on its website, it would always beat competitors’ prices.
Why this matters
These rulings reiterate important guardrails for “lowest price” claims in the rail sector. The ASA requires operators to prove that they will beat, not merely match, competitors’ prices. The regulated nature of rail fares through the TSA, combined with the availability of fee-free tickets from third-party retailers and split-ticketing services, makes absolute “lowest price” claims extremely difficult to substantiate. Train operators and third-party retailers must carefully audit price comparison claims and ensure that robust systems capture all available purchasing routes (including split-ticketing) before making “cheapest” or “best price” assertions. This applies equally to advertisers in other price-regulated sectors where third-party aggregators operate.
