ESG Enforcement Tracker

On 9 September 2026, the ASA handed down three rulings against three travel agencies found to be in breach of the CAP Code. Each travel agent must amend or withdraw the offending advertisements.

DialAFlight, the trading name for Lotus International Ltd, released an ad on Meta in which a video advertising an island resort was accompanied by the text “reconnect with yourself and your surroundings at our eco-conscious resort”. In response to the ASA challenge, DialAFlight stated the claim had been taken from a factsheet provided to them by the resort. The resort operators provided a list of environmental initiatives and activities undertaken at the resort.

Thomas Cook, the trading name for Thomas Cook Tourism (UK) Company Ltd, advertised a resort as an “Eco Resort”. Thomas Cook claimed they had used an ad performance tool to generate part of the ad based on the terms used by customers when searching for accommodation. They argued that the phrase “Eco Resort” appeared automatically in the ad, in response to search terms that were being used by consumers.

Loveholidays, the trading name for We Love Holidays Ltd, released two ads in July 2026 that were both challenged by the ASA. In the first ad, a resort was described as an “Eco Resort”, and in the second ad, a hotel was described as an “Eco Hotel”. Love holidays responded by stating they did not own, operate, or manage the accommodations featured in the ads and were simply displaying third party inventory. The term “Eco” was included with reference to the resort and hotel respectively, as these were the registered trading names of the accommodation suppliers. Loveholidays stated the term “Eco” was used only to properly identify the accommodation by its registered name, not as an environmental claim formulated, adopted, or endorsed by Loveholidays.

The ASA considered, in relation to all three challenges, that the various environmental claims included in the ads would communicate to consumers that the advertised accommodation had some environmental characteristics or benefit. In reference specifically to Loveholidays’ claims, the ASA stated that regardless of the registered names of the accommodation, the ASA considered they would also be understood as a description.

The ASA went on to state that it was essential to provide consumers with sufficient information about the basis of environmental claims so that they could understand what environmental characteristics or benefit were being referred to in relation to that accommodation. That information would then enable the consumer to assess the relevance and significance of those characteristics when deciding whether to proceed on their consumer journey.

The ASA was provided with evidence that each accommodation advertised had taken steps to reduce their environmental impact. However, none of these initiatives were communicated to the consumer and as such the ASA held that each advertiser remained in breach of the CAP Code. All three agencies were found to have not made the basis of environmental claims within the advertisements sufficiently clear, therefore breaching the CAP Code (Edition 12) rules 3.1, 3.3 (Misleading advertising), and 11.1 (Environmental claims). The ASA stressed that the CAP Code requires advertisers to make clear the basis of environmental claims and that unqualified claims could mislead if they omitted material information.

All three of these cases came to the attention of the ASA as part of intelligence gathering into online advertisements of the travel agent sector.