4 steps to check ASA and CAP Code rules for PPC ad copy

What to take away

A PPC agency should treat every ad as a claim that must be substantiated before it goes live.
Four checks cover claims and substantiation, pricing and availability, endorsements and testimonials, and landing page consistency.
ASA Copy Advice is free and confidential, and it should be used before launch, not after a complaint.
Non-compliance can lead to removal of paid search ads, published rulings and Trading Standards referrals.
Google Ads and Microsoft Advertising enforce their own policies on top of CAP Code rules.

Check one: claims and substantiation in PPC ad copy

Every headline, description line and sitelink is an advertising claim. The CAP Code requires that claims are accurate, honest and capable of substantiation before they appear. That applies to superlatives, performance promises and comparative statements alike.

Claims and substantiation checks

Headline, description, sitelinkevery claim
Superlativestrue and evidenced
Performance promisesevidence on file
Comparative claimsfair, like-for-like basis
Health, financial, green claimscloser scrutiny

A PPC agency writing copy for a UK client should keep evidence for each claim on file. If a client cannot produce the evidence, the claim comes out of the ad. The advertising codes published by the ASA and CAP set out those requirements for claims, pricing and substantiation.

Where claims go wrong in search ads

Character limits push writers towards shorthand. "Number one agency" fits in a headline; the evidence behind it usually does not. The same applies to "proven results", "cheapest in the UK" and "award-winning" when no award is named.

Superlatives are not banned. They must be true, and the advertiser must hold evidence that supports them. A claim that a service is the fastest or the largest needs a defined measure and a source.

Comparative claims need a fair basis. If an ad says a service beats a named competitor, the comparison must be like for like and based on verifiable data. Naming a competitor without evidence invites a complaint from that competitor.

Health, financial and environmental claims attract closer scrutiny. Green claims in particular must reflect the full life cycle of the product or service, not one favourable metric.

Substantiation in practice

Substantiation means the advertiser can prove the claim if challenged. Screenshots, dated test results, client data and published research all count. Verbal assurances from a sales team do not.

A simple rule for a PPC agency: if the evidence file is empty, the claim is a liability. Write the ad so it can be defended without the client's help.

A worked example

A Manchester software client wants the headline "Cut payroll costs by 40%". The evidence is one customer's internal report from 2024. That is not enough for a general claim.

Ask the client for data covering all customers, not one.
If the average saving is lower, use that figure or drop the number.
Add a qualifier only if it is genuinely accurate, such as "for SMEs using our standard plan".
Record the source and the date in the compliance file.
Re-check the claim when the client's pricing or product changes.

That process belongs in the account's standard workflow, not in a one-off clean-up. The advertising rules in England apply across the UK, so the same discipline works for Scottish, Welsh and Northern Irish campaigns.

A claims checklist

Every superlative has dated evidence on file.
Comparative claims name a fair, like-for-like basis.
Statistics state the period and the sample.
Health, financial and green claims are checked against sector guidance.
The client has signed off the wording and the evidence.
The evidence file is stored where the account team can find it.
Claims are re-checked when the offer or product changes.

Check two: pricing and availability statements under the CAP Code

Price claims are among the most common sources of upheld complaints. The CAP Code expects advertised prices to be the price the consumer will actually pay. Hidden fees, mandatory extras and charges added at checkout all fall foul of that principle.

Pricing and availability checks

Advertised price equals price consumer pays
VAT, delivery, booking fees stated clearly
Reference price genuine and previously applied
Percentage savings calculated on normal selling price
In stock and next day delivery claims corrected quickly
Free trialno paid subscription required

In search ads, the pressure is worse. A price in a headline or price extension is read as the total. If VAT is excluded, the ad must say so clearly, and the same applies to delivery charges or booking fees.

Discounts and reference prices

A "was £499, now £299" claim needs a genuine previous price. The reference price should have applied for a reasonable period, and the product should have been sold at it. Repeating an inflated reference price to make a discount look larger is a breach.

Percentage savings must be calculated on the correct base. "50% off" means half of the normal selling price, not half of a premium tier.

Availability

"In stock" and "next day delivery" are claims about availability. If stock runs out or delivery slips, the ad must be corrected quickly. Limited offers need a clear end date or a clear statement that stock is limited.

Free offers need care too. "Free trial" should not require a paid subscription to access. If a card is needed to start a trial, say so.

Price extensions and feeds

Price extensions and shopping feeds pull data from a client's systems. A PPC agency should check that the feed price matches the landing page price and the checkout price. Mismatches between the three are a routine cause of complaints.

Set a weekly check on feed accuracy for any account running price extensions. It takes minutes and prevents most pricing complaints.

Sector-specific pricing rules

Financial services, credit and insurance ads must follow additional rules on representative examples and risk warnings. Travel ads must show the total price including taxes and unavoidable charges. Telecoms and broadband ads must state contract length and any mid-contract price rises.

Check three: endorsements and testimonials in search ads

Testimonials must be genuine and used with permission. A quote attributed to a customer who never said it, or who did not agree to its use, breaches the CAP Code. So does a testimonial that no longer reflects the service.

Endorsement and testimonial checks

Testimonials genuine and used with permission
Shortened quotes keep original meaning
Star ratings reflect verified reviews
Review count accurate, negatives not suppressed
Expert endorsement genuine and relevant
Celebrity endorsement clearly identifiable
Trade body claims accurate and current

Search ads rarely have room for a full quote. Sitelinks and callouts often carry shortened versions. Shortening must not change the meaning of the original statement.

Reviews and ratings

Star ratings and review counts shown in ads must reflect genuine, verified reviews. Review platforms have their own policies, and Google Ads and Microsoft Advertising each apply their own checks. A PPC agency should confirm where the rating data comes from and how often it refreshes.

If a client has a small number of reviews, a rating can still be shown, provided the count is accurate. Suppressing negative reviews while displaying a rating is misleading.

Expert and celebrity endorsements

An endorsement by a named expert must be genuine and relevant to the product. A celebrity or influencer endorsement must be clearly identifiable as such. If a commercial relationship exists, the ad must not present the endorsement as independent opinion.

Employee and trade body claims

Claims such as "IPA member" or "CIM accredited" must be accurate and current. Membership lapses. A PPC agency should check trade body and accreditation claims at least annually, and remove them if they no longer hold.

Testimonial checks

Confirm the quote is genuine and unedited in substance.
Hold written permission from the person quoted.
Check the quote still reflects the current service.
Verify any rating or review count against the source platform.
Re-check endorsements and accreditations each year.

Check four: landing page consistency with ad copy

The landing page is part of the ad. The CAP Code applies to the whole consumer experience, and the ASA will look at the page a click leads to when assessing a complaint.

Consistency means the offer, the price and the conditions on the page match the ad. If the ad says "free trial", the page must not require a card before the trial starts without saying so in the ad.

Common mismatches

Ad copy vs landing page

Ad copy

Price: Excludes VAT
Discount code: Valid in ad
Claim: Stated in ad
Form data: Implied fields
Destination: Promised offer

Landing page

Price: VAT-inclusive
Discount code: Expired on page
Claim: Absent on page
Form data: Asks for more
Destination: Different offer or brand

Each of these is fixable, and each is a complaint waiting to happen. A PPC agency should treat the ad and the page as one asset and review them together.

Data protection on landing pages

Lead forms collect personal data. UK GDPR and the Data Protection Act 2018 apply, and the Information Commissioner's Office enforces them. Consent language must be clear, and the privacy notice must be easy to find.

Working with developers and clients

Landing page changes often sit with a client's web team. Build a shared checklist and a change log so the ad and the page stay in step. When a client changes a price or an offer, the ad should be updated in the same window.

This is where ASA enforcement pressure meets day-to-day account work. Rising automation in bidding and creative does not remove the need for a human check on the page.

Using ASA Copy Advice and the AdviceOnline library before launch

The ASA runs a free, confidential Copy Advice service for advertisers and agencies. It reviews proposed non-broadcast ads, including search copy, and gives an opinion on whether they are likely to comply.

Copy Advice workflow

Draft ad copy and landing page headline together
List every claim, price and testimonial
Check each against AdviceOnline for sector
Submit uncertain items to Copy Advice
Record advice and date in compliance file
Re-run check when offer or guidance changes

Copy Advice is not a pre-clearance promise. It is an informed view, and it can save a campaign from a complaint. For regulated sectors, or for a claim the team is unsure about, it is the sensible first stop.

The AdviceOnline library sits alongside it. It covers specific sectors and claim types, and it is searchable. A PPC agency can build a short internal note for each client sector, drawn from AdviceOnline, and reuse it across accounts.

How to use Copy Advice in a workflow

Draft the ad copy and the landing page headline together.
List every claim, price and testimonial in the draft.
Check each against AdviceOnline for the client's sector.
Submit anything uncertain to Copy Advice before launch.
Record the advice and the date in the compliance file.
Re-run the check when the offer or the sector guidance changes.

Turnaround is usually a few working days, so build it into the campaign calendar rather than treating it as an emergency step. For agencies working to tight launch dates, that means drafting earlier.

Building a compliance habit

A short internal checklist, applied at draft stage, catches most issues before they reach a client. Pair it with an annual review of sector guidance and a named compliance owner in the agency.

The rules and ethics that govern UK paid search are stable in principle and detailed in practice. The detail is where complaints live.

What ASA sanctions and Trading Standards referrals mean for agencies

Most ASA cases end with an informal resolution. The advertiser agrees to amend or withdraw the ad, and the case closes without a published ruling. That is the outcome to aim for.

ASA sanctions escalation

Complaint received
Informal resolution: amend or withdraw ad
Non-compliance: published ruling naming advertiser
Search platforms remove paid ads
Serious cases referred to Trading Standards

If an advertiser will not comply, the ASA can publish a ruling naming the advertiser and the ad. The sanctions page sets out the options, which include asking search platforms and social networks to remove paid ads.

Removal from Google Ads and Microsoft Advertising

Search platforms act on ASA rulings. Ads that are the subject of an unresolved ruling can be pulled from Google Ads in the UK. Microsoft Advertising applies its own policies and enforcement, and its advertising solutions sit alongside the CAP Code rather than replacing it.

For a PPC agency, removal means lost spend, lost visibility and a client conversation about why the ads stopped. The reputational cost is often larger than the media cost.

Trading Standards referrals

The ASA can refer persistent or serious cases to Trading Standards. The Trading Standards referrals route gives the ASA a formal enforcement lever where its own sanctions are not enough.

Trading Standards sits within local authority trading standards services across the UK. A referral can lead to investigation under consumer protection law, and in serious cases to prosecution. That is a different order of risk from a published ruling.

What this means for agency contracts

Agencies should be clear about who owns compliance. The advertiser is responsible for the claims it makes, but the agency drafting the copy shares the practical risk. Put a compliance clause in the contract, and agree who signs off claims and evidence.

Keep a record of advice given to clients about claims that were removed or softened. If a complaint arrives later, that record shows the agency acted properly.

Sanctions risk checklist

Every account has a named compliance owner.
Claims and evidence are reviewed before each major campaign launch.
Copy Advice is used for uncertain claims and regulated sectors.
Client contracts cover claim sign-off and compliance responsibility.
Rulings and platform policy updates are reviewed monthly.
A process exists for responding to an ASA enquiry within the deadline.

Costs and practicalities

An ASA enquiry costs time, not fees. Responding properly means gathering evidence, drafting a reply and, in many cases, amending the ad. Agencies that handle this well usually resolve cases at the informal stage.

Budget for compliance time in retainers, especially for regulated clients. It is cheaper than a ruling, and it protects the client relationship.

Common questions

Does the CAP Code apply to Google Ads and Microsoft Advertising copy?

Yes. Paid search ads are non-broadcast advertisements, so the CAP Code applies to the copy, the extensions and the landing page the ad links to.

Is ASA Copy Advice mandatory?

No. It is a free, confidential service, but using it before launch is a practical way to reduce the risk of a complaint on a claim you are unsure about.

Who is responsible if a PPC ad breaks the rules?

The advertiser is responsible for its claims, and the agency that drafted the copy shares the practical risk. Contracts should say who signs off claims and evidence.

What happens if an advertiser ignores an ASA ruling?

The ASA can publish the ruling, ask search platforms to remove the ads, and in serious or persistent cases refer the matter to Trading Standards.

How often should ad copy be re-checked?

Re-check claims, prices and testimonials whenever the offer, the product or the pricing changes, and review sector guidance at least once a year.

Do price extensions need to match the landing page exactly?

Yes. The price in the ad, the price on the page and the price at checkout should match. Mismatches between them are a common cause of upheld complaints.