Veridat
← Resources

ASA & CAP Code

ASA CAP Code Substantiation Checklist

The ASA CAP Code expects marketers to hold evidence for objective claims before they are made. For B2B teams, the risk is often operational: evidence exists somewhere, but it is not connected to the exact claim, final wording, publication context, or reviewer decision. This checklist helps teams create a cleaner substantiation record before publication.

8 min read · Advisory workflow guidance, not legal advice

Who should use this ASA CAP Code checklist?

This checklist is for marketing, legal, compliance, product, and founder-led teams that publish objective claims in the UK. It is relevant whether claims appear on a website, landing page, paid ad, sales deck, product sheet, webinar, case study, or outbound email.

It is especially useful before publishing claims that include measurable outcomes, customer results, comparisons, superlatives, security posture, environmental impact, or regulated sector wording.

What does ASA CAP Code evidence mean in practice?

For workflow purposes, evidence means documentation that supports the likely interpretation of the claim by the target audience. The evidence should exist before publication and should be specific enough to support the wording actually used.

A common failure mode is attaching evidence that is related but not sufficient. A customer quote may support that one customer had a positive experience. It may not support a broad claim that all customers reduce costs by a stated percentage. A benchmark may support a technical performance claim in a defined test environment. It may not support a general market-leading claim.

  • The evidence should match the exact claim wording
  • The evidence should cover the product or service being promoted
  • The evidence should be current enough to rely on
  • The evidence should cover the relevant audience, region, and channel
  • The evidence should explain methodology where numbers or comparisons are used

Which objective claims are most likely to need substantiation?

Objective claims are statements that can be proved or disproved. They often sound factual, measurable, comparative, or externally verifiable. If the audience is likely to interpret the statement as factual, teams should assume evidence is needed before publication.

Subjective puffery can still create risk when it implies factual superiority. The phrase “the smarter way to manage claims” may be low risk in isolation. “The fastest claims governance platform for FCA-regulated teams” is a different type of statement and should be supported or softened.

  • Performance claims, such as saves time, reduces cost, improves accuracy, or increases conversion
  • Comparative claims, such as faster than spreadsheets or better than manual review
  • Superlative claims, such as leading, best, first, only, or most trusted
  • Customer outcome claims, such as teams cut review cycles by 40 percent
  • Security or certification claims, such as SOC 2 Type II certified or encrypted end to end
  • Environmental claims, such as sustainable, lower carbon, recyclable, or net zero

How should teams check whether evidence fits the claim?

Start by writing down the likely claim interpretation. Ask what a reasonable buyer would think the statement means. Then check whether the evidence supports that interpretation, not just the internal intent behind the copy.

For example, “trusted by regulated teams” may require clarity. Does it mean paying customers in regulated industries, pilot users, newsletter subscribers, or general interest from prospects? The evidence and wording should align.

  • What exactly does the audience think this claim means?
  • Does the evidence support the whole claim or only part of it?
  • Does the evidence require qualification or context?
  • Is the evidence independent, internal, customer-provided, or estimated?
  • Is the evidence still current?
  • Would a reviewer understand the evidence without a separate explanation?

What should an ASA substantiation record include?

A good substantiation record should make review and later retrieval simple. It should connect the published wording to the exact evidence used in the approval decision. It should also record conditions, limitations, and the review date.

Email threads and Slack approvals are weak records because they are hard to search, easy to fragment, and rarely preserve the final wording, evidence, and decision together.

  • Final proposed claim wording
  • Channel and publication context
  • Claim category and risk level
  • Evidence links and evidence owner
  • Reviewer name and decision date
  • Approval outcome, including conditions or required qualifications
  • Approved wording for reuse
  • Review date or evidence expiry date

Practical example: performance claim

Proposed claim: “Our platform reduces manual review time by 50 percent.” This should be checked against the basis for the number. Was it measured across all customers, a pilot, an internal workflow test, or a single case study? Does it apply to all users or only certain teams?

A safer approved claim might be: “In a pilot workflow, teams reduced manual review steps by up to 50 percent.” The qualification changes the claim from a broad promise to a scoped statement.

ASA CAP Code substantiation checklist

Use this checklist before publishing objective marketing claims.

  • Have we identified every objective claim in the copy?
  • Have we removed or softened unsupported superlatives?
  • Does each claim have evidence before publication?
  • Does the evidence support the exact wording?
  • Have we checked product, audience, geography, and time scope?
  • Have we documented assumptions, exclusions, and qualifications?
  • Has a reviewer approved the wording and conditions for reuse?
  • Have we set a review date for claims based on changing evidence?

FAQ: Do B2B claims still need ASA-style substantiation?

B2B context does not remove the need for accuracy. If a claim is objective and appears in UK advertising or promotional material, teams should be prepared to substantiate it. Enterprise buyers also increasingly expect evidence for claims before procurement or security review.

FAQ: Can we publish first and gather evidence later?

A safer workflow is to hold evidence before publication. If evidence is not ready, teams should soften the claim, remove it, or mark it as pending review. Veridat is designed around this practical operating principle: evidence-backed claims first, reuse after approval.

Disclaimer

This checklist is informational only and is not legal advice. For specific ASA CAP Code interpretation or regulatory risk decisions, speak with qualified legal or compliance advisers.

Next step

Paste a page of copy into the Claim Risk Checker to find candidate claims and prioritise what needs evidence first.

Try Claim Risk CheckerSee platform