The ruling refers to a national press advert for Lloyds Banking Group, which showed a photo of the iconic black horse galloping past new homes with building work underway.
The text said: “£19.5bn for social housing. And that’s just the start”. This was then followed by smaller text saying: “Everyone deserves a safe place to call home. That’s why we’ve provided £19.5 billion to the social housing sector since 2018. Helping Britain prosper. Search Lloyds Banking Group social housing”.
The complainant said the advert “misleadingly implied” that Lloyds Banking Group had donated £19.5bn to social housing projects.
Lloyds Banking Group argued that the advert was part of a wider campaign that aimed to highlight its “role as a leading commercial supporter of the sector”.
It said that as the advert had been published in The Times, the average reader of The Times would have understood that it was a major banking group and not a charitable or philanthropic organisation and the claim did not imply that the £19.5bn would be given as a donation.
Aldermore Insights with Jon Cooper: Edition 4 – Budget 2025: Landlords feel the heat, brokers to steer the market
Sponsored by Aldermore
The ASA ruled that the meaning “for” and “to” social housing was “ambiguous”, and the advert did not specify whether the money had been donated, lent or invested or make reference to funding having been made available via commercial arrangements.
It added that the image of the black horse galloping past new homes under construction, along with the statement “Helping Britain prosper”, reinforced that impression.
“Taken together, we considered readers were likely to interpret that to mean Lloyds Banking Group had played a direct role in creating affordable housing and the funding had been provided on a non-commercial basis, for public benefit.
“However, we understood the claim related to their role as a financial services provider and that it had been provided to the social housing sector through loans and other financial investment schemes,” the ASA said.
The ruling said it recognised Lloyds Banking Group’s assertion that readers would recognise that as a bank, it would not donate a sum of that size, but it said that due to the time period of seven years the figure referred to, it was “not an inconceivable amount” for a large bank to donate over that time frame.
It also acknowledged Lloyds Banking Group’s comparison with government spending on social housing but said most readers would not be familiar with these figures.
“Notwithstanding those points, we considered that many readers were unlikely to focus on the precise figure listed in the ad, beyond recognising it as substantial. Given the indications in the ad that the initiative was charitable, and in the absence of any information to the contrary, we considered it was reasonable for consumers to assume that the money referred to a donation to the housing sector,” it said.
“We concluded that the overall presentation of the ad, in the absence of any qualification or clarifying text, while ambiguous, gave the overall impression that the sum of money had been donated to the social housing sector. Because that was not the case, we concluded that it was misleading,” the ASA explained.
Consequently, the advert must “not appear again in the form complained of” and Lloyds Banking Group must not “misleadingly imply that they had donated money to social housing projects when that was not the case, and to ensure future ads did not mislead by omitting significant information that put claims into context”.
A Lloyds Banking Group spokesperson said: “We acknowledge the ruling but respectfully disagree with this specific decision. We believe the advert was clear, aligned with the ASA’s standards of responsible advertising and will have been understood by any reasonable reader.
“It accurately reflected our commercial support for the social housing sector, and we remain committed to communicating this impact in a way that is transparent and easily understood by all audiences.”
