Eight questions to ask of an ad before it runs
Each question below comes from the ACCC’s guidance on false or misleading claims, with the matching part of Google’s ad policies where there is one.
Is every claim true, and could you back it up?
Any information or claim about a product or service must be accurate, truthful and based on reasonable grounds, and businesses should be prepared to prove their claims. The ACCC can require a business to back up a claim it makes.
Does the price tell the whole story?
The ACCC lists price claims that can mislead: something offered “free” when conditions apply, a “sale” price that isn’t really a temporary sale price, and a price shown without GST or other costs. Google’s dishonest pricing policy wants the way people will pay, and the total they’ll end up paying, made plain.
Does the fine print agree with the headline?
What the small print says can’t contradict the main message an ad gives. An ad that says “free” and mentions an extra payment in the fine print is likely to be misleading.
Is any comparison fair?
Comparing products or services on price, quality, range or volume can be misleading if the comparison is inaccurate or doesn’t compare them fairly.
Is anything important left out?
Silence can mislead. The ACCC says leaving something out can be misleading, particularly when a business gives some information but doesn’t mention important details relevant to the customer’s decision. Google’s misrepresentation policy also catches ads that mislead by holding back facts people need about a product.
Can you deliver what the ad promises?
The ACCC’s list of what a business shouldn’t do includes offering goods or services it knows it can’t supply, and making promises it can’t keep. Google bars ads whose promised product or offer isn’t there, or is hard to find, once someone clicks through.
Is a claim about the future grounded?
A prediction or projection needs reasonable grounds at the time it’s made, and the business is responsible for showing it had them. Google’s unreliable claims policy rules out dangling an unlikely result as if it were what people should expect, even when it could happen.
Is it clear who the ad is from?
Businesses shouldn’t impersonate or pretend to be a different business or brand. Google wants advertisers to be upfront about who they are, and to use a business name that plainly matches the business behind the ad.
Where the two rule books meet
The ACCC’s guidance comes from consumer law; Google’s policies are the terms of its own platform. They overlap often, and Google’s policy also reaches the ad’s design and the page it leads to.
| Topic | ACCC guidance | Google’s policy |
|---|---|---|
| Prices | Don’t mislead about price; show GST and other costs in it | Disclose the payment model and the full expense clearly |
| What’s left out | Silence about an important detail can mislead | No excluding relevant product information |
| Identity | Don’t pretend to be a different business or brand | No obscuring identity, affiliations or qualifications |
| Results | Claims about the future need reasonable grounds | No improbable result presented as the likely outcome |
| The ad itself | Check the overall impression is accurate | No designs that hide that it’s an ad, or that mimic system notifications |
Exaggeration nobody would believe
Not every big claim is a problem. The ACCC calls wildly exaggerated, vague claims that no one could take seriously “puffery”, and its example is a restaurant claiming the best steaks on earth. Statements like that are generally not considered misleading.
The line is specificity. Claims about a particular quality or benefit should be true, accurate and based on reasonable grounds, and the ACCC warns that broad, vague terms may themselves mislead, because they rarely tell a customer how the claim connects to the product.
What the ACCC says a business should do
- Give current and correct information, in language that’s easy to understand.
- Check that the overall impression is accurate, and be specific.
- Back up claims with facts and evidence, and note important limitations or exemptions.
- Keep customers updated if things change, and correct any misunderstanding.
The rule applies to any communication by a business: advertising, websites, social media, a quotation, testimonials, and whatever staff say, in writing or out loud.
What can happen
If a business misleads, the ACCC can investigate and may take compliance or enforcement action, and there can be penalties. The ACCC also accepts reports from businesses and consumers about possible false or misleading claims, though it doesn’t resolve individual disputes.
Google treats some breaches as egregious, among them conning people by hiding or twisting the facts about a business or what it sells. Those end with the account suspended the moment they’re found, with no warning, and a permanent ban from Google Ads. An appeal is possible, but Google says reinstatement is rare and needs a compelling case.