ASA monthly insights November 2025: Rulings you need to know about

Our advertising and marketing team read the Advertising Standard Authority's (ASA) rulings every week and each month select the ones we think you need to know about and of course, one for fun.

Make a reasonable estimate of demand or be explicit about availability

The Code requires that advertisers make a reasonable estimate of demand when running a promotion. In an investigation into promotions for a £1 railcard, the ASA has restated the point that if availability is limited, this needs to be made clear in the advertising materials: stating it in the full terms and conditions will not be considered sufficient to meet the requirement that consumers need sufficient information, provided in a clear and timely manner to make a decision. 

The ASA considered that two promotions advertising £1 railcards (describing the price as a “mega sale” and a “summer sale”) without further explanation, meant the ads suggested that the offer was a discounted price that applied to any consumers who bought a railcard on the advertised date. In the absence of evidence that the advertiser had undertaken a reasonable estimate of demand, the ads were found to breach the CAP Code and caused unnecessary disappointment. 

Deadline to claim prize ruled a significant condition of entry

Staying with promotions, the ASA ruled against an ad which didn’t state that the winner would have to claim the prize within three days of being notified. The full terms and conditions included this information, it was stated in the “competition details” on the competition landing page, and in the email the winner received. 

However, this was not considered sufficient by the prize winner who was unable to claim their prize and complained that ad omitted significant conditions of the promotion. The ASA agreed, ruling the prize-claim deadline should have been stated in the initial advertising post and that by not doing so the ad was misleading, and the promotion had not been administered fairly. 

Existence of ‘loot boxes’ should be declared

The ASA reviewed three mobile apps containing random item purchasing (“loot boxes”) following a complaint by an academic researcher challenging whether the ads were misleading by omitting material information. The ASA referenced the Committee of Advertising Practice’s (CAP) Guidance on advertising in-game purchases when investigating the ads

The guidance which was published in 2021 and updated in 2024 states that in-game purchasing and random-item purchasing in particular may be material to consumer’s transactional decision in relation to downloading a game. The Guidance notes that the information about loot boxes should be immediately next to (or part of) information about in-game purchasing more generally.

The rulings underline this:

• “Offers in-App Purchases” is not sufficient on its own to indicate that there are loot boxes. The ASA also noted that that loot boxes were not among the 10 items listed as available to purchase.
• Requiring consumers to click "more" and scroll to learn about the existence of loot boxes was not sufficiently clear (being too far from the main call-to-action and not visible at the point consumers were likely to decide whether to download the app, even after expanding the description).

The ASA also ruled that by displaying random purchase items on a prize-wheel with evenly spaced icons, the consumer was likely to understand that the odds of winning each one was equal and whilst the advertiser had followed DCMS working group recommendations by displaying odds within one click, using a question mark was not a clear enough sign to indicate that was where the information about odds could be found.  

Gambling ad provides example of how to exclude under 18s

This month saw Match Bingo successfully defend an ad which included an animated presenter singing a football song and was placed at the beginning and end of YouTube content featuring the Tottenham Hotspur football team (in animated form) singing the same song. In assessing the ad for compliance, the ASA took into account whether it was featured near editorial that would have appeal to children. 

Whilst animated footballers might not instinctively feel compliant, they didn’t appear in the ad itself and the ASA took on board the advertiser’s points that the imagery in the video did not feature cartoon-style or childlike characters and the humour and music featured were not targeted at (or likely to be engaging to) children and young people.

The fact the video was satirical and focused on interactions between players, managers, owners and pundits rather than on gameplay was also pertinent. Significantly, the advertiser was able to show that the YouTube channel’s audience was 91% 18 years old and over and was marked as “Not made for kids” so that the algorithm would direct the content away from children.

The ASA took all these factors into account and ruled that the ad had not been directed at under-18s through the selection of media or context in which it appeared.

ASA AI monitoring and LED face masks

In the first of our product deep dives, we looked at the ASA’s rulings on the ads for LED face masks making medical and medicinal claims for products which did not hold the relevant registrations or licences to do so. 

And finally, one for fun

There wasn’t really a contender for fun ruling of the month in November but as we rush towards Christmas we will feature a ruling from the archives (March this year) in which an alcohol advertiser’s argument that Santa didn’t just appeal to children, but was in fact a “cultural icon” and that they believed that: 

which was not accepted by the ASA based on the way the character of Father Christmas was portrayed.