The UK’s Advertising Watchdog has come under fire after the Independent Reviewer of Advertising Standards Authority adjudications found a serious flaw in the investigation of one of the largest third party websites in the passport industry finding that ASA executives failed to consider research the agency had itself commissioned that would determine whether or not the website would mislead consumers. This serious error has forced the agency to re-open the investigation into the website (case number: A14-273276).

The Advertising Standards Authority has made a strong point in 2014 to clamp down on misleading copycat websites that typically advertise on search engines that provide “document checking” and other services for a fee of £40 – £80 to access government services as has the Committee of Advertising Practice who since October 2014 has taken an active role in closely monitoring copycat sites and taking enforcement action against those who are not compliant with the CAP code.

In September the ASA published its findings of an investigation into website finding that it was likely to mislead consumers into believing that it was a government website and that consumers were likely to believe that they were paying for the passport fee instead of this third parties services. No mention of the IPSOS Mori consumer research was made.

This irregularity prompted an investigation by the Independent Reviewer of ASA judgments, Sir Hayden Phillips who after carefully considering the facts found in early November that the Advertising Standards Authority had made a serious error in their conduct when investigating the complaint. The agency was slammed for failing to reference their own consumer research into copycat websites which focused exclusively on how consumers interact with copycat websites, whether they could tell the difference between the commercial sites and official government websites and findings of what the average consumer found misleading.

The ASA has been accused of white washing the case and having an agenda to find against the website regardless of the facts by Richard Howard the owner UK Services & Support Ltd and the website who claims that the IPSOS Mori research exonerates his website from any claim that it is misleading. He claims the ASA intentionally ignored this research so that they could upheld the complaint and show to government and the media that they’re clamping down on all copycat websites regardless of  whether they abide by the CAP code or mislead customers or not. All third party websites will suffer the same fate he believes.

The ASA were asked comment on why they failed to take into consideration or even mention the IPSOS Mori research when investigating the complaint into an ASA spokesmen replied….

The Advertising Standards Authority refused to make a comment.

When asked why they had not updated the adjudication page to advise the media and public of this serious flaw they replied…

The Advertising Standards Authority refused to make a comment.

Questions have also been raised by Howard over the ASA’s interpretation of the “average consumer”. The law and the watchdogs CAP code defines the average consumer as informed and reasonably observant and circumspect. However Howard blasts the agency for watering down the legal definition to suit the agenda of the ASA investigation. No case would have been opened if the true definition of the typical consumer had been used Howard claims. He also disputes the label “copycat website” for stating that the company offers a package of 25 items for the service fee that it charges with only 3 also available from Her Majesty’s Passport Office.

When asked for comment on why the ASA found that an informed and reasonably observant and circumspect person would be misled by the advertising on when each page contained multiple disclaimers they replied…

The Advertising Standards Authority refused to make a comment.

The Ipsos Mori research also found that the majority of consumers saw the value of copycat websites, did not see the need to have them outlawed or even regulated. also claims to have integrated all of the “best practice” suggestions made by consumers in research and says they do comply in full with the CAP code. Howard claims that this is a clear case of politicians and government agencies ignoring public opinion and pushing forward with their own personal desires.

When asked whether there would be any job losses or disciplinary action brought against those who caused this blunder they replied….

The Advertising Standards Authority refused to make a comment.


Their is NO Adjudication against nor any “Upheld” complaint against the accusation that our website could be confused as a government resource or that customers could be “mislead” into believing that they were paying for the passport fee when using our website. The A14-273276 investigation found at: is no longer active due to the error in the executives investigation.

Those who wish to validate that this is the case should contact the ASA on: 020 7492 2222