Date: 24 05 2023

CNHC's Advertising guidance for Registrants been updated to ensure clarity about the use of Testimonials and Endorsements as follows:  

5. Do Testimonials and Reviews constitute advertising?

5.1. CAP uses the terms testimonials and reviews interchangeably and have advised that they are likely to count as advertising if they are edited or actively incorporated into your own marketing.  If they are not, they are likely to count either as organic ‘user-generated content’ or as editorial content.

5.2. For example, if you have a dedicated section on your website where clients can post testimonials and reviews, and you don’t edit or cherry-pick the testimonials or reviews that they leave (except to carry out basic moderation such as removing anything that is hateful or seriously offensive), then you are unlikely to be considered responsible for the content of those testimonials or reviews. The ASA is only likely to consider that you are responsible for the content of that section of your website if it:  

  • Includes testimonials or reviews that you have collated and gathered from elsewhere, or 
  • is moderated to remove negative ones, or 
  • is re-ordered to draw attention to those that you particularly like, or 
  • if you quote these testimonials or reviews anywhere else. 
  • If you provide a link to an organic review section, this isn’t likely to bring the content of those reviews within the remit of the CAP Code.

5.3. Likewise, if clients publish reviews about you on social media, these reviews aren’t likely to count as ads for your services unless you have incentivised your clients to do so.  However:

  • if you repost these reviews or otherwise ‘quote’ them and incorporate it into your own marketing, then it’s likely to be brought within the remit of the Code
  •  if your advertising links to an individual review that you wish to highlight, there is a risk of bringing that individual review into the remit of the ASA, but if the link is just to a review section or another external site where un-moderated, organic consumer reviews appear, CAP does not think you would be responsible for the content. 

5.4. It is essential to note that if you or your website manager yourselves publish testimonials or reviews on your website you must have the consent of the client to do so and you must hold research evidence to substantiate any claims made in them."

Please read the guidance in full and use it as a resource to check the content of your website and other forms of marketing.

If you have any questions, please don't hesitate to contact us. You can email us at or call us on 020 3327 2720.