Who: The Advertising Standards Authority (ASA) and Contact Solar Ltd (Contact Solar)
Where: United Kingdom
When: 27 August 2025
Law stated as at: 24 September 2025
What happened:
The ASA has upheld a complaint that it instigated itself following identification of an ad potentially in breach of the UK Code of Non-broadcast Advertising and Direct and Promotional Marketing (CAP Code) through its active ad monitoring system. The ruling is part of the ASA’s wider work on the advertising of greener heating and insulation products.
The ad, which appeared on a search engine site, was for Contact Solar and stated “£5,995 Fully Installed Solar – No Deposit Needed”. The ASA investigated the add on two grounds: whether the claim “£5,995 Fully Installed Solar” was misleading and could be substantiated; and whether the ad had failed to make clear all significant limitations and qualifications.
When assessing the ad, the ASA had regard to the Competition and Markets Authority’s (CMA) guidance on “Marketing green heating and insulation products“. The guidance states that consumer prices must be accurate and give a realistic indication of what consumers are likely to pay for a product. Headline prices must also be truthful and clear. Any important qualifications should be presented clearly and prominently as close to the headline price as possible, so that a consumer can easily see them.
The ASA considered that the wording of the ad would lead consumers to understand that Contact Solar was making an absolute pricing claim and that it would charge no more than £5,995 for solar panels and their installation. Contact Solar argued that it expected consumers to interpret the ad as meaning that they could have a 4.3 kW solar panel system installed for £5,995 and that it had evidence that all 4.3kW panel installations in 2025 had cost £5,995 or less. However, the ASA noted, in reality the ad linked through to Contact Solar’s website which outlined the prices of different solar panel packages, including a 4.3 kW package for £5,995, and that the prices were subject to the consumer’s circumstances and Contact Solar’s terms and conditions. Contact Solar also sold packages at a high wattage, suitable for homes with a higher electricity usage, for a greater price. The 4.3 kW packages could also cost more than £5,995 if the consumer’s property had certain additional factors making the installation of the panels more complex.
The ASA considered this to be material information that was likely to affect consumers’ understanding of the ad’s price claim, and therefore needed to be included in the ad. The ad itself had used 219 characters, and the ASA considered that there was sufficient space to make clear the package details and the circumstances that could impact the price of installation.
Because the ad omitted material information and had not been substantiated, the ASA concluded that it was likely to mislead.
Why this matters:
Marketers must ensure that they provide all material information about pricing in their advertisements. Omitting material information from an invitation to purchase is a prohibited practice under both the Digital Markets, Competition and Consumers Act 2024 (DMCCA) and the CAP Code (as updated in light of the DMCCA coming into effect). Rule 3.4 of the CAP Code specifies the total price of the advertised product in the list of material information that must be included in ads quoting prices. It also states that if the whole or any part of the total price cannot be calculated in advance, marketers must set out how the price will be calculated.
The CMA has also published guidance on the unfair commercial practices provisions under the DMCCA, which explains the requirements for an invitation to purchase. Businesses should take this guidance into account, as non-compliant businesses now risk scrutiny from both the CMA (who now has direct enforcement powers) in respect of consumer protection law and the ASA under the advertising codes
