ASA CAP Code: the rules for dental advertising in the UK

The ASA CAP Code is the rulebook for non-broadcast advertising in the UK, and for a dental practice it covers far more than most owners expect: your website, your Instagram, your Google ads, your leaflets and the reviews you quote. The Advertising Standards Authority enforces it, and dental and cosmetic claims are an area it has ruled on many times. This guide covers what the code is, the rules that matter most for dental advertising, and a simple check before anything goes live.

What is the ASA, and what is the CAP Code?

The Advertising Standards Authority (ASA) is the UK's independent advertising regulator. It enforces two codes, both written by industry committees:

• The CAP Code, the UK Code of Non-broadcast Advertising and Direct and Promotional Marketing, written by the Committee of Advertising Practice. This covers websites, social media, search ads, print, posters, email and direct mail.
• The BCAP Code, the UK Code of Broadcast Advertising, which covers TV and radio ads.

Almost everything a dental practice does is non-broadcast, so the CAP Code is the one you need. GOV.UK's page on advertising codes of practice explains how the codes sit alongside the law. The full CAP Code is published on the ASA website, section by section, and can be downloaded as a PDF from the same page.

Does the CAP Code apply to your practice website?

Yes. Claims on your own website and on social media accounts you control are within the ASA's remit. Its sanctions page sets out what it can do when non-compliant claims appear there: list your business and the problem on a dedicated part of the ASA website, ask search engines to remove paid ads that link to the offending page, run its own paid search ads highlighting the non-compliance, and work with social media platforms to have content removed. Persistent offenders can be referred to Trading Standards.

The GDC runs in parallel. Its guidance on advertising requires advertising to be accurate and not misleading, and warns that misleading advertising is unprofessional and may lead to a fitness to practise investigation. A ruling from one body is not a defence with the other.

The CAP Code rules that matter most for dental ads

Section 3 (misleading advertising) and Section 12 (medicines, medical devices, health-related products and beauty products) do most of the work for dentistry. These are the rules worth knowing by number:

The wording is CAP's, summarised. Read the full rules in Section 3 and Section 12 before relying on any of them.

What does CAP Code 3.7 mean?

Rule 3.7 means you must have the evidence before the ad goes out, not after someone complains. In CAP's words, marketers must hold documentary evidence to prove claims that consumers are likely to regard as objective and that are capable of objective substantiation, and the ASA may treat a claim as misleading if adequate substantiation is missing.

For a dental practice, an objective claim is anything a patient could in principle check: "pain-free", "lasts a lifetime", "straight teeth in six months", "the most experienced implant team in the area". For treatment claims, rule 12.1 adds that evidence should, where relevant, consist of trials conducted on people. Your own impression, or a manufacturer's brochure, is rarely enough. If you cannot prove it, rewrite it as something you can, such as describing what the treatment involves and who it suits.

Before and after photos

Before and after photos are the most common source of dental complaints, and the rules are clear. CAP's advice on before and after photos says the ASA treats them in the same way as testimonials. That means:

• The photos must be genuine, and you should hold signed and dated proof that they are and have not been manipulated.
• You need the patient's permission to use them, and their contact details on file.
• They must not exaggerate the result, and should be reasonably representative of what most patients can expect.
• Lighting, angle and retouching count. Digitally enhancing an "after" shot to exaggerate whitening is a breach.

The GDC's standards add a confidentiality layer: images of patients are confidential information, and you must not make recordings or images without the patient's permission. Get written consent that covers marketing use specifically, not just clinical records.

Reviews and testimonials

The CAP Code now has specific rules on consumer reviews. Rule 3.44 bans fake consumer reviews outright. Rule 3.45 says ads must make clear where reviews have been incentivised. Rule 3.46 says you must not publish reviews in a misleading way, and gives examples such as removing negative reviews while publishing positive ones, or giving positive reviews more prominence than negative ones.

That has a practical consequence for practice websites. A hand-picked carousel of five-star quotes, presented as if it were your whole review record, is exactly the kind of thing rule 3.46 describes. A live feed of your Google reviews, or a clear statement of your overall rating and review count, is safer. Testimonials still need to be genuine, held on file with the patient's contact details, relevant to the treatment advertised and used with permission, under rules 3.47 to 3.50. For how to handle the reviews themselves, see our guide on replying to Google reviews.

Prices, "from" prices and free consultations

Three rules cover most dental price advertising. Rule 3.17 says price statements must not mislead by omission, undue emphasis or distortion. Rule 3.22 says "from" and "up to" prices must not exaggerate how available the benefit is. Rule 3.23 says you must not call something free if the patient has to pay anything beyond the unavoidable cost of responding.

In practice: if your implant page says "from" a figure, a meaningful share of patients should actually pay that figure. If the "free consultation" leads to a charged assessment or X-rays before anything useful happens, say so in the ad. The GDC's standards point the same way, asking practices to give clear information on prices on their websites.

The "Dr" title, specialists and Botox

Three dental-specific issues come up again and again:

1. "Dr". CAP's advice on the term "Dr" for dentists recommends that if you use it, you make clear and prominent that it is a courtesy title and that you do not hold a general medical qualification. In a 2013 ruling the ASA found a dentist's use of the title misleading without that clarification, even though the dentist was entitled to the courtesy title.
2. "Specialist". Under the GDC's advertising guidance, only dentists on a GDC specialist list can call themselves a specialist or use titles such as Orthodontist or Periodontist.
3. Botox and facial injections. CAP's general dental advice reminds practices that some products in this sector, including Botox, are prescription-only and cannot be advertised to the public. CAP's before and after guidance adds that before and after images of a prescription-only product are very likely to be seen as an ad for it, even without any claims.

Whitening and braces claims

CAP's advice on teeth whitening says marketers must hold evidence that a product or service can genuinely whiten teeth, must not exaggerate results through digital manipulation of images, and must not promise fast or one-use results without evidence. A claim that a product could whiten teeth by three shades failed because the advertiser could not substantiate it.

On braces and aligners, CAP's enforcement notice on braces and dental devices says not to claim that a system is "less painful" or has a "faster effect" than traditional braces, because that would need high-quality human clinical trials CAP has yet to see. It suggests talking instead about how they look, how they make the wearer look, or that they are easier to clean if you can show it.

What adverts has the ASA banned in dentistry?

The ASA's published advice gives a clear picture of where dental advertising fails. Rulings it cites include:

• A dentist's ad that used "Dr" without making clear it was a courtesy title (2013).
• A dental practice's before and after photos (2017), a ruling CAP cites when it says marketers should hold signed and dated proof that photos are genuine.
• Several teeth whitening products whose efficacy claims, speed claims or before and after images were not supported by adequate evidence (for example in 2012, 2019 and 2021).

The pattern is consistent. Rulings rarely turn on clever wording. They turn on missing evidence, missing consent and missing qualifications.

How to check a dental ad before it goes live

1. List every objective claim in the ad, including what the images imply. For each one, find the evidence on file. If there is none, rewrite or remove it.
2. Check every photo. Genuine, unretouched in any way that affects the result, signed and dated consent for marketing, patient contact details held.
3. Check the price. Does a "from" figure reflect what real patients pay? Is anything called free actually free?
4. Check titles. "Dr" qualified as a courtesy title. "Specialist" only for those on a GDC list.
5. Check the treatment. No prescription-only medicines. For social posts, a line that the treatment may not suit everyone and depends on an assessment, as the GDC requires.
6. When unsure, ask CAP. The Copy Advice service reviews non-broadcast ads before publication, with a standard turnaround of 3 to 5 working days and paid options for faster answers.

The same discipline applies to search ads, where the headline space is short and the temptation to overclaim is strongest. Our guides to Google Ads for dentists and social media marketing for dentists cover the channel detail.