The Advertising Standards Authority (ASA) has today published a batch of rulings against major retailers over price claims in Black Friday and promotional advertising. The decisions, involving well known high street names such as Boots and Debenhams, form part of a wider group of investigations into Black Friday price promotions, identified through the ASA's Active Ad Monitoring system, which uses AI to proactively scan for online ads that may breach the rules.
The common thread running through all four rulings is the requirement that savings claims must be substantiated against a genuine usual selling price, and the need to hold detailed information to support such claims. The ASA applied the CTSI Guidance for Traders on Pricing Practices throughout, reinforcing its expectation that retailers must be able to demonstrate, with detailed pricing and sales data, that any "was" price or reference price used in advertising genuinely reflects the price at which a product was ordinarily sold (for a sufficient period, in sufficient quantities).
Key takeaways
These rulings collectively reinforce several important principles for retailers and advertisers:
- When it comes to reference pricing, the CMA may be sitting on its hands as it awaits the outcome of the Emma Mattress case (due to be heard in June 2026), but this is not holding back the ASA.
- The ASA expects detailed pricing and sales history data to substantiate any savings claim. Assertions about usual selling prices will not suffice without documentary evidence. They expect a detailed breakdown of the product's price on different days over a fairly lengthy period (e.g. at least three months) and how many units were sold each day at that price point.
- A product must have been available at the reference price for a meaningful period. A brief period at a higher price, particularly immediately before a promotional event, will not establish that price as the genuine usual selling price.
- Marketplace operators bear advertising responsibility for claims made on their platforms, even where pricing is set by third-party sellers.
- Human error or system failures do not excuse non-compliance. Retailers must have adequate systems and controls in place to prevent outdated or inaccurate pricing data from generating misleading savings claims.
- The ASA's Active Ad Monitoring system — which uses AI to proactively identify potential breaches — signals an increasingly interventionist approach to enforcement. Retailers should expect that pricing claims in online advertising will be subject to scrutiny, whether or not a consumer complains.
Let's look briefly at each decision:
Boots UK Ltd t/a boots.com - Upheld in Part
The ASA investigated two ads for Boots broadcast during the Black Friday period. The first promoted a Yankee Candle gift set with a "was £60, now £29.50" claim. The second promoted a BOSS Bottle Beyond fragrance with a "was £80, now £60" claim.
Boots stated that the Yankee Candle gift set had been sold at £60 for 54 days between August and October 2025, and at the promotional price of £29.50 for 41 days, before reverting to the higher price after the promotional period. It had also sold approximately 15,000 units at £60 and 40,000 at the promotional price. This isn't quite the 1:2 ratio that the CMA is keen to adopt in the mattress industry, but isn't far off.
The ASA found that the Yankee Candle "was" price was not misleading. The product had been available at the higher price for longer than the promotional price, and a significant volume of sales had been made at £60, which was sufficient to establish it as the genuine usual selling price.
However, the BOSS fragrance had only been sold at £80 for 21 days following its launch in September 2025. It had subsequently been offered at £64 and then £60, meaning it had been available at the promotional price for substantially longer than at the reference price. The ASA concluded that £80 had not been established as the genuine usual selling price and the savings claim was therefore misleading.
The ruling was upheld in relation to the BOSS fragrance ad only.
You'll find the full ruling here.
Debenhams (DBZ Marketplace Online Ltd) - Upheld
The ASA investigated two video display banner ads for Debenhams. The first, seen on 29 November 2025, advertised a bed with a "-44%" discount label, showing a price of £349 against a struck-through price of £619. The second, seen on 4 December 2025, advertised a hair styling tool with a "-21%" discount, showing £379.99 against a struck-through £479.99.
Debenhams argued that it operated as a marketplace provider and that third-party sellers were responsible for setting their own prices. It contended that, with more than 20,000 partners, it would be unreasonable to expect individual monitoring of each product's pricing.
The ASA rejected this defence. Because Debenhams hosted the offers on its website, it was responsible for ensuring those offers represented a genuine saving.
On the merits, Debenhams did not provide detailed sales or pricing history for either product. The ASA noted that the bed had been advertised at £349 since April 2025 — more than six months — making it unlikely that £619 represented the usual selling price. The hair styling product had similarly been discounted several times in the preceding six months and the saving claim had not been made against the price immediately preceding the ad.
Both ads were found to be misleading.
This ruling is notable for its confirmation that marketplace operators cannot simply delegate compliance responsibility to their third-party sellers — the platform that hosts the ad bears responsibility for the claims made within it.
You'll find the full ruling here.
Very (Shop Direct Home Shopping Ltd) - Upheld
The ASA investigated two product pages on the Very website, seen on 10 February 2026. The first advertised a ceramic coffee table at £129 with a "Save £150" claim against a struck-through price of £279. The second advertised a dining table and chairs set at £299 with a "Save £50" claim against a struck-through price of £349.
The complaint was brought by Which?, the consumer protection group.
Very accepted that both ads were non-compliant. In relation to the coffee table, the product had been discontinued in July 2025 and the "was" price of £279 should have been manually suppressed but was not, due to human error. The pricing data showed the product had been offered at eleven different prices between £116 and £279 in the preceding six months, and had only been available at £279 for six days.
For the dining set, Very explained that the product had been sold at £349 for only 69 days in the six months before the ad appeared, compared to 114 days at £299 or less. The "was" price should similarly have been suppressed from 18 December 2025 onwards but was not, again due to human error.
The ASA concluded that neither "was" price represented the genuine usual selling price and the savings claims were misleading.
The ruling underlines that human error in failing to suppress outdated pricing data does not provide a defence — the obligation is to ensure that any savings claim appearing on a retailer's website is accurate at the time consumers see it.
You'll find the full ruling here.
John Lewis plc - Upheld
The ASA investigated two ads: a paid Facebook ad for a MacBook Air claiming a £150 saving, and an online display ad for an ASUS Zenbook claiming a £450 saving. Both appeared in November 2025 as part of Black Friday promotions.
In relation to the MacBook Air, the retailer stated that the £150 saving was calculated against the immediately preceding price of £849. However, the retailer did not provide detailed pricing or sales data sufficient to demonstrate that £849 was the established usual selling price.
In relation to the ASUS Zenbook, the retailer stated the product had been sold at £1,099 for 47 days before being reduced to £649 for Black Friday. Interestingly, the ASA stated it expected to see at least three months of pricing history, including information about how long the product was sold at each intervening price, in order to assess whether £1,099 was genuinely the usual selling price, and the retailer did not provide sufficient data to satisfy the ASA, so the ASA upheld in relation to both ads.
You'll find the full ruling here.
What does this mean for discount price claims?
As mentioned above, while the CMA is keeping its powder dry when it comes to reference prices, and while the CMA's proposed approach seems slightly at odds with the ASA's own approach, the ASA is plowing ahead with applying its own interpretation of the CTSI Guidance on Pricing Practices. We are likely to see more ASA rulings when it comes to reference prices, and later this year (or early 2027) we are likely to see the CMA get stuck in on this issue, too.
For more information about the CMA's activities in this area, visit our consumer law hub.