Original article ISPreview UK:Read More
The UK Advertising Standards Authority (ASA) has today banned yet another direct mailing advert for alternative full fibre broadband ISP Zzoomm, which occurred after it was found that the mail was NOT “obviously identifiable as a marketing communication” and misled recipients about the importance of its content.
In short, Zzoomm sent out a direct mail (letter) to homes in some of their deployment areas, which on the front was marked “Important notice. Disruption in your area” – indicating some urgency. But the letter inside said: “Not the disruption you were expecting…But it’s the best kind. Homes across your area are switching to faster, more reliable Full Fibre broadband from Zzoomm – loving the difference…”.
Issues like this one have cropped up before. For example, ISPreview recently ran a piece that questioned the boundary between ethics and advertising when using exactly this sort of tactic (here), which often makes such letters look like an urgent government, police or HMRC communication etc. Unsurprisingly, the ASA noted how five people complained about Zzoomm’s similar letter and promptly upheld those complaints.
In its response, Zzoomm agreed with the concerns raised and pointed out that the relevant marketing campaign was designed and distributed by a team that no longer worked with them. The campaign was conceptualised in April 2025, before a new team was appointed in June 2025, following their merger with FullFibre Limited (here). “They had no knowledge of the campaign and therefore did not review it. They said that, had they been given the opportunity, they would not have circulated the campaign,” said the ASA.
ASA Ruling (REF: G25-1297639 Zzoomm plc)
The ASA considered that the text “Important notice. Disruption in your area” implied that the letter received was an official communication related to an interruption of service in the recipients’ local area. We further considered that the text “Important notice” indicated a sense of authority to recipients. We also noted the appearance of the envelope, which was brown and windowed. We considered that this further contributed to the overall impression that the circular was official correspondence.
While we acknowledged the presence of the Zzoomm logo on the envelope, we considered that, the inclusion of branding alone was not sufficient to make clear the commercial nature of the communication, particularly when presented alongside wording that suggested an important service update.
In that context, we considered that the contents of the envelope would be understood to contain a formal notice about potential disruption to the recipients’ usual broadband service in the local area. Furthermore, we understood that Zzoomm had previously carried out infrastructure improvements in the relevant areas, and we thus considered that furthered this impression.
The letter stated “Not the disruption you were expecting…But it’s the best kind. Homes across your area are switching to faster, more reliable Full Fibre broadband from Zzoomm […]” and “Broadband disruption… but for all the right reasons”. We considered that, once opened, most recipients would understand that the letter was a marketing communication promoting Zzoomm’s broadband offering. However, because that text was not visible without opening the letter, we considered that it was not obviously identifiable as a marketing communication.
Because the ad implied it contained an important notice about broadband disruption in the recipient’s local area and did not make its commercial intent clear from the outset, we concluded that the ad was misleading and breached the Code.
The ruling is important because it sends a clear signal to the rest of the industry that it is not appropriate to adopt this sort of tactic with Direct Mailing adverts. This is likely to impact a number of other providers (e.g. like the one we previously highlighted in our aforementioned article) as some of those communications were even less obviously promotional than Zzoomm’s.
As usual the ASA banned the advert in its current form (a move Zzoomm had already taken) and told the internet provider to ensure that their ads were “obviously identifiable as marketing communications, and that they did not mislead consumers by presenting them in a way that implied they were important notices about broadband disruption“.
We should point out that this is not the first time Zzoomm has been at the wrong end of the ASA’s ban hammer (here), albeit previously for a different issue.