Rules and ethics
Part of When to check local service marketing rules and ethics before you advertise
Briefing subcontractors on local service advertising rules
Brief staff and subcontractors on what your local service firm may claim in ads, what proof backs each claim and how to handle consent.
What to take away
- A claim made by a subcontractor on a doorstep can still be treated as your advertising.
- A one-page brief lists the claims people may make and the evidence file behind each.
- Claims such as "same-day callout" or "fully insured" need evidence before anyone uses them.
- Quoted prices include VAT and compulsory charges, whoever gives them.
- A named person reviews new wording, and a complaints log records any regulator contact.
- This covers England; Scotland, Wales and Northern Ireland differ in some areas.
Anyone who speaks for the firm can create an advertisement
A claim made by a subcontractor on a doorstep can still be treated as your advertising. Local service businesses often use subcontractors, and their conduct reflects on your brand, so anyone who speaks for the business needs a written brief on what they can and cannot say.
GOV.UK says that as well as the regulations, there are two advertising codes of practice to follow, and that you must describe your product or service accurately: the CAP Code for non-broadcast ads and the BCAP Code for broadcast ads. The CAP Code covers ads wherever they appear, including a single Facebook post or a leaflet through a door in England.
Refer to the brief in the subcontractor's written terms, and keep a dated copy of the version each person received. How commercial contracts are structured shows where such a clause can sit.
List the claims people may make, and the proof behind each
Claims about response times, qualifications or prices must be evidenced before anyone publishes or says them. Ads must be legal, decent, honest and truthful, and you must hold evidence before publishing. The brief turns that rule into a short list of permitted statements.
| Claim | Evidence to hold | If a customer asks for more |
|---|---|---|
| "Same-day callout" | Records showing the service can be delivered that day | Say the office will confirm the timing |
| "Fully insured" | Current insurance documents covering the work | Offer written confirmation |
| A price | A figure that includes VAT and compulsory charges | Quote the total, not part of it |
| "Cheaper than the other plumber in town" | A like-for-like comparison of equivalent services | Do not say it unless the comparison is on file |
One quick job is not evidence of a general promise. If the firm advertises "same-day callout", the file should show it can be delivered as a rule, not as a lucky exception, and the brief should say who updates the evidence when capacity changes.
Comparative claims, such as "cheaper than the other plumber in town", must compare like with like. If you cannot substantiate one, do not run it. Price claims need to include VAT and compulsory charges, so staff quoting on the doorstep use the same figure as the ad.
Teach the contact rules in three lines
Whoever collects a phone number or email address must know three things: marketing consent is a separate, positive choice, texts and emails to individuals need that consent, and call lists must be screened. Each belongs in the brief as one plain sentence.
The Information Commissioner's Office (ICO) says, in its UK GDPR guidance, that all consent must be opt-in consent, meaning a positive action or indication, and that there is no such thing as "opt-out consent". So the quote form carries a separate unticked box for marketing, and staff never tick it for the customer.
Valid vs invalid consent
Valid consent
- Customer action
- Ticks empty box
- Silence
- Not consent
- Quote request
- Separate marketing box
- Record
- When and how kept
Invalid consent
- Customer action
- Box pre-ticked
- Silence
- No objection
- Quote request
- Auto-added to list
- Record
- No proof held
A quote request form might say "Please contact me about my quote" with a required email field, then a separate unticked box: "I would like to receive marketing about other services". Keep the date, source and exact wording of each consent, and let your disclosure policy say in plain English what you collect and why.
For calls, screen numbers against the Telephone Preference Service and re-screen at least every 28 days. A firm that buys a list and rings through it is taking a real risk. Electronic marketing to individuals needs consent under PECR, and sole traders count as individuals.
Review before publication and log what comes back
Name one person who reviews every new ad, leaflet or social post before it goes live, and give that person the evidence file. A reviewer who has never seen the proof can only check spelling. The review is where the brief meets real wording.
- Every factual claim has written evidence on file.
- Prices include VAT and compulsory charges.
- Comparative claims compare equivalent services.
- Staff and subcontractors hold the current written brief.
- Consent is recorded and kept separate from the quote request.
- Any call list has been screened against the Telephone Preference Service.
- A named person has reviewed the wording.
- The complaints log is up to date.
Keep a complaints log that records any regulator contact, and respond promptly. The Advertising Standards Authority (ASA) can publish an adverse ruling, issue an Ad Alert to media, ask search engines to remove paid ads, and refer persistent offenders to Trading Standards. The wider UK regulations, including the Digital Markets, Competition and Consumers Act 2024, sit outside this brief.
This is general guidance only, so individual cases need a qualified adviser. The checks that hold after launch are in a quality checklist for local service marketing.
Common questions
Do these rules apply to a single Facebook post?
Yes. The CAP Code covers ads in any medium, including social media and leaflets. A one-off post making a claim is still an ad, so the person posting needs the same brief as the person writing the leaflet.
Can a subcontractor's doorstep claim count as my advertising?
Yes. A claim made by a subcontractor on a doorstep can still be treated as your advertising. Brief anyone who speaks for the business on what they can and cannot say, and refer to the brief in their written terms.
What should staff do when asked about a claim that is not on the list?
Not make it. Note the question, pass it to the named reviewer and answer only once the evidence is on file. A claim you cannot substantiate should not run, whether it is printed on a leaflet or said on a doorstep.
