Email me

The CAP Code for dental practices: what the ASA looks for

Last reviewed against the regulators’ own text, linked in the sources below.

This is general information, not legal advice.

On this page
  1. In short
  2. Who the ASA is
  3. The rules that matter
  4. Substantiation
  5. Comparisons
  6. Enforcement and rulings
  7. Sources

The ASA judges dental advertising against the CAP Code, and for practices the rules that matter most are in section 3 (misleading advertising) and section 12 (medicines and health). In plain terms: hold evidence before you make a claim, do not exaggerate results, compare fairly or not at all, and never advertise a prescription-only medicine to the public.12

What the ASA has said about dentistry is organised below by the thing you're publishing, followed by how it enforces the code. The ASA is the only rulebook covered. The GDC, finance, consumer law and platform rules are on the page mapping every rulebook that governs dental marketing.

This is general information, not legal advice. Last reviewed: 1 October 2026.

Who the ASA is

The Advertising Standards Authority (ASA) is the UK's independent advertising regulator. The Committee of Advertising Practice (CAP) writes the rulebook it enforces for non-broadcast media: the CAP Code, formally the UK Code of Non-broadcast Advertising and Direct and Promotional Marketing.

The part practice owners miss is scope. The code applies to marketing by businesses "on their own websites, or in other non-paid-for space online under their control", where it's connected with selling their services.3 Your treatment pages, your Instagram grid and your Facebook posts are all in scope, not just the ads you pay for.

The ASA and the General Dental Council (GDC) act independently. The GDC deals with you as a registrant; the ASA deals with the ad. The same headline can breach both.

The rules that matter

The code has 22 numbered sections.7 For a private dental practice, most of the risk sits in a handful of rules.12

CAP ruleWhat it requires, in short
3.1Ads must not materially mislead or be likely to
3.3Ads must not omit material information
3.7Hold documentary evidence for objective claims
3.11Do not exaggerate what a product or service can do
3.17 and 3.18Price statements must not mislead; quoted prices include non-optional charges
3.22"From" and "up to" claims must not exaggerate availability
3.33 to 3.38Comparisons must be fair and verifiable
3.44 to 3.50Reviews, testimonials and endorsements: genuine, permitted, not fake or hidden-incentive
12.1Objective health claims need evidence, "if relevant consisting of trials conducted on people"
12.2Do not discourage essential treatment
12.12No advertising of prescription-only medicines to the public
12.18No health professionals or celebrities endorsing medicines
12.25No cosmetic intervention ads directed at under-18s

The ASA's "Dental: General" advice applies those rules to dentistry. Here it's organised by asset:4

What you publishWhat the ASA's dental advice saysRules engaged
Treatment page for aligners or bracesDo not exaggerate what the product can do; hold evidence "in the form of clinical trials"3.7, 3.11, 12.1
Whitening page or adDo not exaggerate results "through digital manipulation of imagery"; hold evidence it genuinely whitens3.7, 3.11
Before-and-after imagesMust be "genuine and representative", with "signed and dated proof"3.7, 3.47, 3.50
Team page and biosDentists using "Dr" must not imply a general medical qualification3.1
Injectables pagePrescription-only medicines "cannot be advertised to the public"12.12
Product recommendationsDentists may endorse cosmetics, not medicines such as medicinal toothpastes12.18
Comparison with a competitor's product or serviceComparisons must be "fair, honest and verifiable" and backed by evidence3.33 to 3.38

Some of these have their own pages. Images: what you can show in before-and-after images. Whitening, which also has a legal restriction on who may provide it: teeth whitening advertising rules. Patient reviews and quotes: the rules on reviews and testimonials. Prescription-only medicines: Botox and facial aesthetics. The "Dr" title: specialist and professional titles.

Substantiation

Substantiation means holding evidence that proves a claim before you publish it. Rule 3.7 requires "documentary evidence to prove claims consumers regard as objective and capable of objective substantiation".1 For health claims, rule 12.1 adds that the evidence should, where relevant, come from "trials conducted on people".2

In practice, the ASA reads an objective claim as anything a patient could check. Common dental examples:

ClaimWhy it needs evidenceSafer approach
"Pain-free implants"An absolute claim about every patient's experienceDescribe the anaesthetic and sedation options instead
"Implants that last a lifetime"A durability claim with no universal evidence behind itState what affects how long implants last
"Straighter teeth in 3 months"A time-to-result claimSay treatment length varies and is confirmed at assessment
"The best implant dentist in town"A superiority claim that is hard to proveDescribe experience factually, without ranking
"5-star rated"A factual claim about reviewsLink to the live source and keep it current

Evidence has to exist when the ad goes live. The ASA's complaint process asks advertisers under formal investigation for "copies of full studies with the relevant sections highlighted".5 If you could not send that for a claim today, rewrite the claim.

The GDC reaches a similar place by a different route. Its guidance tells registrants to "back up claims with facts" and avoid claims likely "to create an unjustified expectation about the results you can achieve".9

Comparisons

A comparative claim is any claim that sets your practice, clinicians or prices against someone else's, named or not. The CAP Code allows comparisons with identifiable competitors only if they compare like with like, do not create confusion and, for prices, make the basis clear.1 The ASA's dental advice adds that comparisons need evidence and must be "fair, honest and verifiable".4

Dentistry has an extra layer. The GDC bars practice websites from displaying information "comparing the skills or qualifications of any dental professional" with those of others.9 So even a comparison the ASA might accept can breach the GDC guidance.

Price comparisons go stale quickly. If a competitor changes a price, your comparison becomes misleading the same day, so I avoid them in evergreen pages.

Enforcement and rulings

The ASA doesn't pre-clear ads. It acts on complaints and on its own monitoring.

What the ASA's own pages say about each step:

  • One complaint is enough. "A single complaint can be enough for us to take action if there appears to be a problem under the rules."5
  • Informal resolution leaves no public record. "Informally resolved cases aren't put before the ASA Council, so no ruling is published."5
  • Formal cases end in a published ruling. The ASA Council is "the independent jury" that decides, and rulings are published every week.5
  • Sanctions are reputational and practical, not fines. The ASA can list non-compliant advertisers on its website, ask search engines to remove paid-search ads, place its own paid-search ads highlighting the advertiser's name, work with social platforms to remove content, and refer cases to Trading Standards.6

The ASA's rulings database is public and searchable by sector. Reading recent dental and aesthetics rulings is the fastest way to see how the code is applied. I do not name practices here. The ASA's own 2024 warning to dental advertisers picked out the recurring themes: before-and-after images without evidence, whitening, and efficacy claims that go further than the evidence.10 Its Botox guidance lists several rulings against clinics that referred to the medicine on social media, including in hashtags.11

Next, the rules on before-and-after photos apply the same evidence test to images. To have your ads and treatment pages read against the CAP Code, email Fayez@imfayez.com; the first read, from the outside, is free.

Sources

  1. CAP Code, section 3 (Misleading advertising), rules 3.1, 3.3, 3.7, 3.11, 3.17, 3.18, 3.22, 3.33 to 3.38 and 3.44 to 3.50. https://www.asa.org.uk/type/non_broadcast/code_section/03.html (accessed 1 October 2026). ↩ ↩2 ↩3 ↩4 ↩5

  2. CAP Code, section 12 (Medicines, medical devices, health-related products and beauty products), rules 12.1, 12.2, 12.12, 12.18 and 12.25. https://www.asa.org.uk/type/non_broadcast/code_section/12.html (accessed 1 October 2026). ↩ ↩2 ↩3

  3. CAP Code, "Scope of the Code". https://www.asa.org.uk/type/non_broadcast/code_folder/scope-of-the-code.html (accessed 1 October 2026). ↩ ↩2

  4. Advertising Standards Authority, "Dental: General", updated 16 March 2022. https://www.asa.org.uk/advice-online/dental-general.html (accessed 1 October 2026). ↩ ↩2 ↩3

  5. Advertising Standards Authority, "How we handle complaints". https://www.asa.org.uk/about-asa-and-cap/the-work-we-do/how-we-handle-complaints.html (accessed 1 October 2026). ↩ ↩2 ↩3 ↩4 ↩5

  6. Advertising Standards Authority, "Sanctions". https://www.asa.org.uk/codes-and-rulings/sanctions.html (accessed 1 October 2026). ↩ ↩2

  7. CAP, "The CAP Code" (non-broadcast code contents). https://www.asa.org.uk/codes-and-rulings/advertising-codes/non-broadcast-code.html (accessed 1 October 2026). ↩

  8. Advertising Standards Authority, "Use of the term 'Dr': Dentists", updated 30 March 2020. https://www.asa.org.uk/advice-online/use-of-the-term-dr-dentists.html (accessed 1 October 2026). ↩

  9. General Dental Council, "Guidance on advertising", effective from 30 September 2013. https://www.gdc-uk.org/standards-guidance/standards-and-guidance/gdc-guidance-for-dental-professionals/guidance-on-advertising (accessed 1 October 2026). ↩ ↩2

  10. Advertising Standards Authority, "This is not a drill: dental ads wisdom", 9 May 2024. https://www.asa.org.uk/news/this-is-not-a-drill-dental-ads-wisdom.html (accessed 1 October 2026). ↩

  11. Advertising Standards Authority, "Anti-ageing: Botulinum toxin products", updated 29 October 2025. https://www.asa.org.uk/advice-online/anti-ageing-botulinum-toxin-products.html (accessed 1 October 2026). ↩