Course pricing claims under the CAP Code: checklist

What this checklist covers

This checklist is for UK non-broadcast marketing communications advertising a course, package or series of non-surgical body treatments. It focuses on the way an advert communicates the commercial offer: the stated amount, number of sessions, included treatment areas, compulsory extras, availability, promotional terms and payment arrangements.

The central framework is Section 3 of the CAP Code, headed Misleading Advertising. CAP writes the UK Code of Non-broadcast Advertising and Direct and Promotional Marketing, while the Advertising Standards Authority, usually called the ASA, considers complaints within its remit. The Code applies to the overall impression created by an advert, not only to its headline. An image, caption, booking button, small-print condition, social-media story frame or automated follow-up message can all affect that impression.

Check the whole consumer journey. A social-media post may lead to a consultation form, then a booking page, then a payment screen. Information revealed only after a consumer has given contact details, booked an appointment or begun a payment process may not correct a misleading initial impression. Material information should be available when it is likely to affect a transactional decision.

This is a pre-publication checklist, not a finding on any individual advert. It does not determine whether a treatment is clinically suitable, whether treatment claims are substantiated, or whether a person should buy a course. Those are separate questions from whether the advertised commercial terms are clear.

Decision rule: If a consumer needs to ask what is included, what else must be paid, whether they can obtain the stated amount, or what deadline applies, before they can understand the offer, the advert needs clearer information at that stage.

Checklist: identify exactly what the stated amount buys

1. State whether the amount is for one session or the full course. A prominent figure should not leave a reader to infer whether it covers one appointment, a fixed number of appointments or all sessions considered necessary. CAP Code rules 3.1 and 3.3 address misleading claims and misleading omissions. Put the session count close to the stated amount where that count defines the offer.
2. Identify the treatment and area where these affect the amount. A course may apply only to a particular body area, treatment type or treatment configuration. If those distinctions change what the consumer receives or what they must pay, they are likely to be material. Do not rely on a general image or an undefined course name to communicate a limitation.
3. Address unavoidable charges. CAP Code rule 3.18 concerns quoted prices and non-optional taxes, duties, fees and charges. Where a consultation, assessment, booking charge, mandatory product or other cost is unavoidable for all or most consumers responding to the offer, presenting the headline amount alone may give an incomplete impression.
4. Distinguish a deposit from the total commitment. A deposit can be stated, but it should not be presented in a way that suggests it is the total course amount. Make clear what remains payable, when it becomes due and whether the deposit is treated differently if an appointment is changed or cancelled.

A course is commonly a single purchasing decision rather than a series of unrelated appointments. The advert should therefore allow a reader to understand the commercial commitment without needing to infer essential terms from later sales discussions.

Checklist: test starting amounts and availability

1. Use a starting amount only where it is genuinely obtainable. CAP Code rule 3.21 says that "from" claims must not be used if a significant proportion of consumers responding to the offer are unlikely to obtain the advertised good or service at the stated amount. The rule requires evidence about real availability, not an assumption that one theoretical configuration is enough.
2. Explain the variable that changes the amount. Where the amount depends on the body area, treatment type, number of sessions or another relevant factor, identify that factor in plain language. A starting amount should not conceal the reason most respondents may be quoted more.
3. Do not treat a consultation as a cure for an unclear headline. A consultation may be needed to assess suitability or develop a plan. It does not remove the need for a non-misleading initial advert. If the intended audience will usually need a different course or a higher amount, that context matters when deciding whether the starting amount fairly represents the offer.
4. Make significant availability restrictions clear. CAP Code rules 3.29 to 3.31 address availability and avoiding unnecessary disappointment in promotions. Restrictions such as particular days, a limited allocation, a defined treatment area or eligibility limited to new customers should be expressed where consumers see the offer, not introduced after they seek to book.

Terms such as "from", "selected areas", "new customers" and "consultation required" are not automatically misleading. Their meaning must be sufficiently clear for the audience addressed by the advert. Keep records showing which configurations were available at the starting amount and how the figure was used in practice during the campaign.

Checklist: substantiate savings and time-limited promotions

1. Identify the comparison behind every saving claim. "Save", "was", percentage-off and similar statements tell consumers that there is a real price advantage. The comparison should be clear: for example, whether it is against the advertiser's own previous course amount or against separately purchased sessions. The compared offers must be materially equivalent.
2. Retain evidence before publication. CAP Code rule 3.7 requires advertisers to hold documentary evidence for objective claims before distributing or submitting a marketing communication. For a previous-price claim, retain records of the earlier amount, the course configuration, when it applied and the circumstances in which it was available. A label alone does not establish a saving.
3. Compare like with like. A course for one area, number of sessions or included service should not be compared with a differently configured course without explaining the difference. CAP Code price-comparison provisions require comparisons to be clear and fair. The more conditions attached to either side of a comparison, the more likely those conditions are material.
4. Ensure urgency is real. A countdown, stated end date or limited-time claim implies a genuine time boundary. Keep a campaign record showing the offer start, intended end, terms and any later changes. Repeating or extending a stated deadline can alter the impression created by the original urgency claim.

A short promotion can be presented fairly. The key question is whether consumers can see its important restrictions in time to decide. CAP Code rule 3.17 requires significant limitations and qualifications to be made clear. A qualification should clarify the main claim, rather than reverse it in wording that is difficult to find, read or understand.

Checklist: present instalments and finance carefully

1. Do not present an instalment as though it were the whole amount. A periodic figure may be useful, but it should not dominate the advert so completely that readers miss the total amount payable. Explain the number of payments, their timing and any deposit or final balance that forms part of the arrangement.
2. Distinguish credit from a payment plan. A finance arrangement and an informal instalment arrangement can have different terms, parties and consequences. Marketing should enable a reader to understand which arrangement is being described rather than using broad affordability language that obscures the structure.
3. Give material qualifications appropriate prominence. CAP Code rules 3.3 and 3.17 are relevant where an apparent offer depends on eligibility, a particular payment schedule or other important conditions. If a main claim is displayed in a social-media graphic, key limitations should not be confined to wording that is visually weak, absent from a short-form format or available only after a booking step.
4. Explain payment timing before commitment. Consumers should be able to establish when a deposit, instalments and any balance fall due before they proceed. Where cancellation, rescheduling or missed appointments can affect their payment obligations, that may also be material information in the context of the offer.

CAP Code Section 14 contains rules relating to financial products and services. Section 3 still matters to the overall presentation of price and material information. Where an arrangement may involve regulated credit or complex contractual terms, specialist legal or regulatory advice may be needed in addition to this advertising checklist.

How to keep evidence and review the finished advert

Create an evidence file for each campaign version before it goes live. It should identify the exact course advertised, included sessions, applicable areas, stated amount, compulsory charges, availability restrictions, promotion dates, comparison basis and payment wording. Preserve the customer-facing material as well as internal notes, including graphics, captions, story frames, landing pages, booking screens and automated messages.

Use a screen test before publication. View the advert on the device and format in which the audience is expected to see it, especially a mobile screen for social-media content. Ask whether a reader can identify the treatment and session count, understand the amount they may have to pay, see why a starting amount may vary, assess a claimed saving and understand any deadline or payment structure.

If an advert is already live, preserve dated screenshots before changing it. The ASA considers the specific marketing communication and evidence before it. A retained record makes it easier to check what consumers actually saw and whether later amendments addressed the initial presentation.

Limits of this checklist

This checklist applies to UK non-broadcast advertising for courses of non-surgical body treatments. It does not cover surgical procedures, clinical assessment, suitability, treatment safety, evidence for efficacy claims, product classification or professional standards. It also does not provide a complete account of consumer-contract, cancellation, data-protection, credit or financial-services law.

The CAP Code is applied in context. Placement, prominence, audience, medium, surrounding wording and the likely overall impression can all matter. A condition that may be clear on a detailed booking page might not be clear enough when a short-form advert makes a strong headline claim. Conversely, the appropriate presentation may differ between a small poster, a social-media story and a multi-page website.

Meeting this checklist does not mean a course is suitable or good value for a particular consumer. It only addresses whether the commercial claim is presented in a way that is less likely to mislead. Consumers may still need to consider their personal circumstances, the full terms and whether they want to make a commitment before proceeding.

This page is not a substitute for legal advice on a particular campaign or complaint. It is also not a prediction of an ASA ruling. Where a claim is unusual, a comparison is complex or payment terms are difficult to explain briefly, the safer editorial approach is to simplify the offer or provide the material information more directly.