Test whether your purpose claim survives a difficult question

The UK advertising regulator ruled HSBC's climate posters misleading because of what they left out. A five-question test to run before any purpose claim goes public.

A purpose claim sounds convincing in a campaign meeting. The real test comes when a regulator, journalist or customer asks a question the campaign did not answer.

HSBC’s 2022 ruling from the UK’s advertising regulator shows what happens when a claim fails that test. It also offers a practical way to test your own.

The HSBC ruling

On 19 October 2022, the UK Advertising Standards Authority (ASA) ruled against two HSBC posters seen at bus stops in Bristol and London in October 2021.

One said HSBC was “aiming to provide up to $1 trillion in financing and investment globally to help our clients transition to net zero”. The other said HSBC was “helping to plant 2 million trees” in the UK.

The ASA received 45 complaints, including from the campaign group Adfree Cities. They challenged whether the ads omitted significant information about HSBC’s own contribution to carbon dioxide and greenhouse gas emissions.

HSBC’s defence and the decision

HSBC argued that its climate strategy was consistent with recognised net zero pathways, including targets for reducing financed emissions in high-emitting sectors.

The ASA said consumers would understand the ads to mean HSBC was making a positive overall environmental contribution as a company. It noted the posters appeared in the run-up to the COP26 climate summit, but did not think that meant consumers understood the details of the transition to net zero.

The regulator pointed to HSBC’s own 2021 annual report. It said the report put the bank’s financed emissions at the equivalent of around 65.3 million tonnes of carbon dioxide a year for oil and gas alone.

It noted that HSBC was continuing to significantly finance businesses and industries that emitted notable levels of greenhouse gases.

The regulator said consumers would not know that, and that it was material information likely to affect their understanding of the ads’ overall message. It concluded the ads omitted material information and were misleading.

The ASA ruled that the ads must not appear again in the form complained of. It told HSBC to make sure future environmental claims were adequately qualified and did not omit material information about its own contribution to emissions.

Why the claims failed

The posters were not false in a narrow sense. HSBC did have financing targets and did support tree planting. The problem was what the ads left out.

That is the most common way purpose claims fail. A true statement about one good activity creates a misleading impression of the whole company.

The UK competition regulator makes the same point. The CMA’s Green Claims Code, published in 2021, sets out six principles, including that claims must not omit or hide important relevant information and must consider the full life cycle of a product or service.

The difficult-question test

Use this five-question test before a purpose claim goes public. It works for environmental claims and for other values-led promises, such as fairness, diversity or local sourcing.

1. What is the strongest objection?

Ask what an informed critic would say first. For HSBC, it was continued financing of high-emitting industries.

Write the objection in one sentence. If the team cannot agree what it is, invite someone outside marketing to name it.

2. Would an ordinary reader know the answer?

The ASA’s reasoning turned on whether consumers would know the missing information. If your audience would be surprised by the answer to the strongest objection, the claim needs more context.

3. Does the claim describe part of the business or all of it?

A claim about one product, programme or site is safer when it says so. Avoid wording that implies the whole company behaves that way.

4. Can you show the evidence today?

List the data, certifications or audits that support the claim. The Green Claims Code says claims must be substantiated, so evidence should exist before publication, not after a complaint.

5. What would you say if challenged in public?

Draft the answer you would give a journalist or regulator. If the honest answer undermines the claim, change the claim.

Running the test in practice

Put the claim, the strongest objection and the evidence on one page. Review it with someone from legal or compliance and someone from the business area concerned.

Include your agency in the review. HSBC’s posters were created by an agency, as most campaigns are, and creative teams need the strongest objection in the brief, not after the artwork is finished.

Record the outcome: approve, rewrite or drop. Keep the page, so you can show how the claim was checked if it is questioned later.

A worked example

Hypothetical: an Irish logistics company wants to advertise “greener deliveries” after adding 40 electric vans to a fleet of 600 diesel trucks.

The strongest objection is obvious: most deliveries still use diesel. An ordinary reader would assume more of the fleet had changed.

The company rewrites the claim to “40 electric vans now serve our Dublin city routes”, adds a link to its fleet transition plan and drops the broader phrase. The details are illustrative.

Beyond environmental claims

The same logic applies to any values-led message. A company promoting fair pay should expect questions about its supply chain. A firm claiming to champion small businesses should expect questions about how it treats small suppliers.

The question is always the same: what would a fair-minded critic say we left out?

What leaders should take away

HSBC’s ruling did not depend on proving the ads false. It depended on what they left out.

Build the difficult question into approval, not into the crisis plan. It is cheaper to rewrite a poster than to explain a regulator’s ruling.