Rules and ethics
Part of Before you publish affiliate claims, check the five rule sets
Substantiating SEO tools ad claims under the CAP Code
A practical checklist on SEO tools advertising claims: CAP Code rules 3.1 and 3.7, ASA enforcement, and the sources that back an accuracy claim.
What to take away
You run paid search for a rank tracking product from a Bristol office. Your ad copy says 'the most accurate rankings in the UK'. Three things apply before that line goes live.
- Advertising in the UK is covered by the CAP Code, and the ASA can act on a complaint without a court case.
- The Electronic Commerce (EC Directive) Regulations 2002 set information duties for online services.
- Every objective claim needs documentary evidence you could show the ASA on request.
- Campaign landing pages should meet WCAG 2.1 level AA wherever you can manage it.
- This article is general guidance. Individual cases need a qualified adviser.
Where the UK advertising rules come from
The Advertising Codes are written by the Committee of Advertising Practice and enforced by the Advertising Standards Authority. They cover paid search, display, paid social and influencer posts aimed at UK consumers.
UK ad rules: who does what
- CAP writes the Advertising Codes
- ASA enforces the codes
- Codes cover paid search, display, social, influencer
- Consumer protection law sits alongside
If you are building the wider picture on data, contracts and renewals, the UK compliance guide for SEO tools sets out the surrounding duties before you write ad copy.
The CAP Code and who it covers: rule 3.1 and rule 3.7
Substantiation is where software marketing most often runs into trouble. If you cannot evidence a comparison, the ASA can require you to change or withdraw it. Read the advertising codes published by the ASA and CAP directly, because a complaint is judged against that wording and not against a summary.
Rule 3.1 covers misleading claims. Rule 3.7 requires documentary evidence before a communication is distributed, for any claim that consumers would regard as objective and capable of objective substantiation — 'the most accurate rankings in the UK' included. Where substantiation is inadequate, the ASA may treat the claim as misleading.
The ASA publishes each ruling as upheld or not upheld; an upheld ruling means the ad must be changed or withdrawn. Repeat breaches can be referred to Trading Standards.
E-commerce information duties under the 2002 Regulations
The information duties for commercial communications apply to any online service, from an ad headline to a product page. In practice, an ad should make clear who is behind it, what the price is, and how to complain. The Electronic Commerce (EC Directive) Regulations 2002 remain the reference point for those duties.
Keeping a source register for ad claims
What counts as a supporting source
A usable source is dated, named and reproducible. That means an ONS release, regulator guidance, platform documentation that defines a metric, or your own test data with a written method. A vendor blog post asserting a speed advantage is not a source.
For a ranking claim, the evidence has to match the claim. Your own test data works when the method is written down: the keyword sample, the search location, the device and the date range. Metric documentation supports a definition rather than a comparison, such as the Google Search Console help page on impressions, logged with the date you checked it. Neither an audience statistic nor a vendor blog post settles 'the most accurate rankings in the UK'.
Worked example: costing the evidence
Take an illustrative three-person team in England. It pays £450 a month for rank tracking, £300 a month for a content brief tool, and £120 a month for screenshot archiving. That is £870 a month, or £10,440 a year, on tool labels alone.
Add claim checking. Eight hours a month at £35 an hour is £280 a month, or £3,360 a year. The combined illustrative figure is £13,800 a year. These are planning numbers, not market averages.
Checking ads before they run
Pre-launch checks for copy and landing pages
Walk the ad, the landing page and the checkout as a stranger would. Check the claim in the headline, the qualifier in the small print, and whether the price shown matches the price charged. Fix mismatches before spend starts.
Landing pages also need to work with assistive technology. The W3C How to Meet WCAG (Quickref Reference) lists the criteria; start with contrast and text alternatives.
Recording evidence and reviews
Keep the register in a spreadsheet or a ticketed queue; the fields matter more than the tool.
| Field | What it holds |
|---|---|
| Claim | The exact wording that goes live, including any qualifier |
| Source | A named release, guidance or platform definition, with its own date |
| Date checked | The day you last opened the source and confirmed it still says what you need |
| Reviewer | The named person who signed the claim off |
| Review trigger | What forces a fresh check, such as a vendor data change or a metric redefinition |
Review the register whenever a vendor changes its data or a metric definition shifts.
If your team publishes comparison pages as well as ads, label paid placement separately from editorial ranking. A disclosure policy for SEO tools is the quickest way to keep those two things from blurring.
Common questions
Do these rules differ across the UK?
The advertising codes apply across the UK. Where a duty rests on devolved law, check the regulator for Scotland, Wales or Northern Ireland rather than assuming the England position carries over.
Can I repeat a vendor's accuracy claim in my own ads?
No. You take on the substantiation burden once the claim appears in your advertising, even if the wording came from a supplier deck.
How long should I keep claim evidence?
There is no single period for advertising substantiation. Keep evidence for as long as the ad runs, plus a margin for complaints, and write that rule into the register.
Who enforces this in England?
The ASA handles CAP Code complaints. Consumer protection law sits with the CMA and with Trading Standards services, whose structure differs across the UK; the Consumer Protection from Unfair Trading Regulations 2008 are the mainstay for misleading commercial practices. Borderline claims deserve a review by a qualified adviser.
