Who: The Advertising Standards Authority (ASA), GGRS Energie Ltd (GGRS Energie) and Good Energy Ltd (Good Energy)
Where: United Kingdom
When: 26 November 2025
Law stated as at: 12 January 2026
What happened:
Using its AI-powered Active Ad Monitoring system, the ASA has identified several advertisements that promised a reduction in energy bills for consumers that installed greener heating and insulation products.
An ad for GGRS Energie appeared in the regional press featuring claims that solar energy could “Drastically Reduce Bills“. A paid-for social media ad for Good Energy included claims that “low-carbon homes”can “save over £1000 a year in bills” and “You can save up to £1,341 in bills”. The ASA challenged whether:
- the price saving claims in ads could be substantiated; and
- the ads failed to make clear to consumers all significant qualifications and limitations applicable to the potential price savings.
The UK Code of Non-broadcast Advertising and Direct and Promotional Marketing (CAP Code) requires advertisers to hold documentary evidence to prove claims that consumers are likely to regard as objective and that are capable of objective substantiation. “Up to” price claims must not exaggerate the availability or amount of benefits likely to be achieved by the consumer. The ASA also considered sector-specific Competition and Markets Authority (CMA) guidance on marketing green heating and insulation products, which states that words and statements that overstate the benefits of a product should be avoided and that ads should not suggest guaranteed outcomes where a consumer might not achieve the claimed benefit or results depend on other conditions. Marketers should present qualifying information clearly and as close to the relevant claim as possible. The guidance also states that “up to” price claims need to be supported with credible evidence that at least a significant proportion of consumers would be likely to achieve the stated outcome and that the claim reflects the range of factors which impact product performance.
Upon reviewing the information provided by GGRS Energie, outlining the financial benefits of installing a solar energy system, the ASA considered that the estimated savings set out in those sources varied depending on consumers’ individual circumstances, such as the type and size of their home, location and their overall energy usage etc. Accordingly, not all consumers could achieve a “drastic” reduction to their energy bills as claimed by GGRS Energie.
Further, the ASA had not received evidence that GGRS Energie’s customers had actually achieved a significant reduction to their energy bills. GGRS explained that factors such as geography, a consumer’s previous energy supply and how their property had been built, could impact the amount of money a consumer could save on their energy bills by having solar panels installed. However, the ad did not refer to any of those factors. Despite the ad stating that a free quote was available, the ASA did not consider that the basis of the savings claim was sufficiently made clear in the ad itself, nor did the ad explain how much money could be estimated to be saved by installing solar panels, or what factors impacted their efficacy. The ASA considered that this was material information likely to affect consumers’ understanding of the ad and was required to be stated in the ad.
In relation to the Good Energy ad, the ASA considered that consumers would understand from the claim “homes with improvements such as solar panels, a battery, insulation and a heat pump cost less to run” that having any one of these upgrades could achieve the promised savings. Good Energy relied on annual running cost saving calculations for a specific type of property (a three-bedroom, semi-detached new-build with several low‑carbon features). The ASA considered that the basis of the savings claim – including the type and size of home, the full range of low-carbon upgrades and the fact that the savings figures were modelled – was material information. Further, the customer data provided by Good Energy did show the possibility to achieve a saving of at least £1,341 on their energy bills annually, however, this level was dependent on customers installing multiple upgrades to their products, rather than simply installing one home improvement product.
The ASA considered that neither ad was limited by time or space to such an extent that the material information could not be provided.
The ASA concluded that as the ads omitted material information in relation to the factors which could affect the amount of money a consumer could save and the savings claims had not been substantiated, they were misleading.
Why this matters
Environmental claims, including those in the energy sector, remain a priority for the ASA. Marketers should have regard to both the CAP Code and sector-specific guidance to ensure their ads contain all the necessary information, including important qualifications, are supported by appropriate evidence, and do not overstate the benefits – whether in terms of price savings, environmental credentials or otherwise – of a product or service.
