Customer testimonials in UK marketing: the evidence, permission and disclosure the CAP Code expects

Rule 3.47 requires documentary evidence that a testimonial or endorsement is genuine, unless it is obviously fictitious, and contact details for whoever gave it. CAP splits genuine into two parts: the quote comes from a real person, and it reflects what they said. Hike Footwear failed in 2024 with no evidence and no contact details for the testimonials in three Facebook ads. Branshaws passed in 2023 with written testimonies, signed, mostly dated, with contact details, and the ASA added that stock images beside genuine testimony were acceptable.

Signed statements are one route. Emails with the customer's address and order history satisfied the ASA (Monark, 2013), as did a combination of email addresses, order numbers and payment system data matching the reviews (Swann, 2020). Emails from unverifiable addresses alone fall short, though a provable company address has been accepted (de Verde, 2013). Rule 3.50 requires permission before a testimonial is featured; marketers who could show none have lost (Easylife, 2020; Conservatory Outlet, 2013), and quoting a published source still needs evidence the quote is accurate.

Two 2024 rulings reset expectations. Zoe ran an ad with a quote from Steven Bartlett encouraging people to try a product, laid out like a customer review; he was an investor in Zoe, and the ASA held that this was material information the ad omitted. Huel attributed this is Huel's best product to the same person; he was a director, and his financial interest was again material.

Rule 2.3 covers the extreme case: a marketer may never pose as a consumer, so writing reviews of your own products as a customer breaches the Code. Since April 2025 the same conduct is a banned practice under consumer law, with the CMA able to fine a business up to 10% of turnover.

Rule 3.48 requires testimonials to relate to the product advertised, in context. Simmer cut footage from a rival's Dragons' Den appearance to look as though it had been endorsed (2024). A review of one track was used for a whole album (Atlantic Records, 2011). Testimonial photos showing another company's product suggested the testimonials were other than genuine (Airbrush, 2026). Altering old testimonials to fit a renamed business, or carrying an employee's praise over from a past employer, has also been ruled against.

Rule 3.52 bars trust marks, quality marks and claims of approval, endorsement or authorisation without the authorisation behind them, with the terms met. A rehab referral service used the Care Quality Commission mark while unregistered (2024); several energy firms implied government endorsement with crown logos and GOV.UK wording (2024); a counselling service claimed BACP accreditation it could show no evidence of (2025); and a currency firm implied FCA regulation (2024). Rule 3.53 bars false claims of signing a code of conduct.

The rules describe the minimum, and the minimum also happens to be what a careful buyer wants: a named person, a real situation, a result that matches the service on the page. A testimonial that says which client the business suits does more positioning work than ten that say the team was lovely.

The businesses that struggle with rule 3.47 are usually the ones whose testimonials were never specific enough to need a record. Specific praise comes with its own evidence attached.