Too close for comfort – A look into the Advertising Standards Authority and the case for more controls on advertising.
This hard-hitting report by Adfree Cities analyses data on complaints to the Advertising Standards Authority (ASA), revealing that only 22% of complained-about adverts are investigated and only 2% upheld. The ASA’s rules are set by ad industry insiders.
We make the case for an independent regulator that is transparent, involves the public in decision making, and can enforce stronger rules – e.g. on the environmental impact of adverts.

Watch the 60-second video
Watch the Webinar
Watch the webinar: ‘Junk food, fossil fuels and consumerism – how can we stop manipulative advertising?’
Recorded from a live session on 14th April 2021.
00:00 mins – Why the advertising regulator is failing to regulate. (Speaker: Carla Denyer, Policy & Press Coordinator at Adfree Cities)
10:01 mins – How new advertising codes against gender stereotyping were implemented following huge public outcry about body-shaming adverts in 2016 (Speaker: Robbie Gillett, Director at Adfree Cities)
15:56 mins – Fossil fuel company advertising: why the ASA is missing the big picture on fossil fuel adverts. (Speaker: Clemens Kaupa, Vrije Universiteit Amsterdam)
28:10 mins – Plus: why some campaigners are bypassing the ASA to tackle misleading advertising by major polluters like BP and Shell.
36:00 mins – Junk food advertising: is the ASA doing enough? (Speaker: Fran Bernhardt, Childrens Food Campaign)
Read more
Read the article: ‘New report exposes failures of advertising regulator‘
See our working
Statistics in the report are calculated based on information in the ASA’s annual reports 2009 to 2019, available here. For more details about our working see the spreadsheet here.
Since the report
ASA fails to act on greenwash ads in 2021-2022
During 2021, following the release of the Too Close For Comfort report, we asked the ASA to investigate misleading and greenwashing adverts by several major polluters, including Chevron, Qatar Airways, Easyjet, HSBC and Jaguar Land Rover. All were considered to be in breach of the advertising codes produced by the Committee of Advertising Practice (CAP), including those for Environmental Claims.
Read a summary of these five complaints and the reasons given by the ASA for failing to investigate or take action.
In June-July 2022, Adfree Cities also submitted complaints about heavily promoted adverts by two of the UK’s biggest fossil-financing banks, Barclays (the top financier of fossil fuels in Europe, and major funder of plastics and deforestation) and Standard Chartered Bank. The ASA refused to investigate.

Chevron “Investing in lower-carbon technologies“: Not investigated

Qatar Airways “Fly Greener“: Not investigated

Easyjet “Destination Zero Emissions“: Not investigated

Land Rover “Beyond Restrictions“: Investigated, no action taken.
The ASA found this ad to be “socially irresponsible”. However, the ruling was overturned at the final stage.
> Land Rover ruling explained: in the Guardian and The Drum.

HSBC “Sustainability“: Investigation ongoing.
An investigation into HSBC’s ‘Sustainability’ ads, which were deployed during COP26 in November 2021, is ongoing. This ad campaign has long since ended in its Out Of Home and print format.

Barclays “Helping to finance the transition to a low-carbon economy“: Not investigated
More information in our blog

Standard Chartered Bank “Here for Good” ads: Not investigated
More information in our blog.