Who: The Advertising Standards Authority (ASA), Accor (UK) Ltd, Booking.com BV, Hilton Worldwide Ltd and Butlins Skyline Ltd
Where: United Kingdom
When: 19 November 2025
Law stated as at: 16 January 2026
What happened:
The ASA has published a series of rulings concerning hotel advertisements using “from” prices and urgency claims.
‘From’ price claims
Several advertisers included “from” prices in their ads for hotel bookings, for example:
- Paid-for website ads for Accor stated: (a) “ibis budget Birmingham Centre from £27”; and (b) “ibis budget Sheffield Arena from £33”.
- A paid-for search ad for Booking stated “Places to stay in Sheffield – Best Price Guarantee” and “easyHotel Sheffield City Centre From £28”.
- Paid-for search ads for Hilton stated “Hampton by Hilton Hamilton Park From £68” and “Best Rates When Booked Direct […] Hampton by Hilton Newcastle From £59”.
The ASA challenged whether these price claims were misleading and could be substantiated. In its assessment the ASA, among other things, relied on rule 3.22 of the UK Code of Non-broadcast Advertising and Direct and Promotional Marketing (CAP Code), which requires that “up to” and “from” price claims must not mislead by exaggerating the availability of the advertised product. The Committee of Advertising Practice’s guidance on availability in travel marketing also states that the availability of a product at the “from” price should be spread evenly across the advertised travel period to which an offer related.
The ASA considered that consumers would expect a significant proportion of rooms to be available at the advertised prices. It expected the advertisers to hold evidence, in the form of pricing and availability data, to demonstrate such availability across a range of dates. Such data should have included information about the number of rooms available at the advertised price and the number available at other prices, to allow a comparison to be made.
In relation to Accor’s ad (a), the ASA understood that the £27 price was only available on 30 July 2025. Despite many rooms being available at this price on that day, since the ad did not indicate the date on which they were available, the ASA considered that availability of the advertised price was not evenly spread across a period of time and concluded that the price claim was misleading. Ad (b), in the ASA’s view, was adequately substantiated and was not misleading as Accor had provided data showing availability and pricing data for 176 dates between April and October 2025, which demonstrated that a significant proportion of rooms had been available for £32.56, and the ASA considered that the dates on which that price was available were spread evenly throughout that time period.
In the ASA’s view, the data provided by Booking was insufficient. The data showed seven bookings at £28 in May 2025, but lacked information such as the number of dates on which rooms were available for £28, which did not allow the ASA to make an adequate assessment of the proportion of rooms at the hotel available at the advertised price.
Hilton’s evidence showed that rooms were available at the advertised prices on the dates the ads were seen but lacked specific data regarding the number of rooms available at those prices, rendering the substantiation inadequate.
Urgency claims
An ad for Butlins Skyline, received via email, included claims such as “THE BIG BUTLIN’S SALE ENDS IN 4 DAYS”, “Time is running out”, “So, what are you waiting for?” and “Take advantage of some great savings when booking by Tuesday 1 July”. The ASA understood that the closing date was later extended to 15 July and challenged whether the promotion breached the CAP Code.
Under rule 8.17.4.e of the CAP Code, promotions’ closing dates must not be changed unless unavoidable circumstances beyond the promoter’s control make it necessary and either: (i) not changing the date would be unfair to those who sought to participate within the original terms; or (ii) those who sought to participate within the original terms will not be disadvantaged by the change.
The ASA considered that the claims in the ad were likely to pressure consumers into booking a break with Butlins before the stated date. However, the ASA understood that the promotion was subsequently extended to allow more consumers the opportunity to benefit from the savings. The ASA considered that this did not constitute unavoidable circumstances outside the promoter’s control which made the change necessary, as required by the CAP Code. The ASA therefore concluded that the promotion had not been administered fairly and had breached the Code.
Why this matters
These rulings underscore that, when making “from” price claims, marketers must hold robust evidence demonstrating that a meaningful proportion of rooms (in the context of hotel advertisements) or other products, as applicable, is available at the advertised price throughout the stated period, with clear disclosure of the relevant dates. Offers promoted with urgency claims, such as “last chance”, “ends tonight” or countdown timers, should not be extended unless truly unavoidable circumstances apply, as required by the CAP Code.
