ScotRail's website, seen on 25 August 2025, told visitors to 'Get cheapest tickets' on the journey planner page, 'Book direct for our best price' on the page's main image, and 'Unbeatable on price' under the Buy Tickets tab of its 'Find the right ticket' page. A single complainant challenged whether the three claims were misleading.

ScotRail defended the wording: the journey planner highlighted the cheapest fare returned, including whether split-ticketing was available; rail fares were set centrally through the Rail Delivery Group's database, and ScotRail charged no booking fees, unlike some third-party retailers, so direct customers always paid the lowest price it offered. Its price promise reimbursed genuine lower like-for-like Seasons or Anytime fares found elsewhere. During the investigation it removed the 'Unbeatable on price' claim.

The ASA upheld the complaint on 24 December 2025. Consumers would read the claims as lowest-price guarantees implying there was no point shopping elsewhere — and such claims must be backed by evidence that ScotRail would always beat, not merely match, competitors. Some third parties also charged no booking fee; there was no evidence ScotRail beat split-ticketing prices offered elsewhere; and the price promise covered only certain ticket types. The complainant had found cheaper tickets for a journey on another service. The ad breached CAP Code rules 3.1, 3.3 and 3.7.

The ruling was one of a set published the same day from the ASA's wider investigation into 'lowest' or 'cheapest' price claims in online rail advertising, which also caught other operators and ticket sellers.

No fine: the ASA upheld the complaint under CAP rules 3.1, 3.3 and 3.7 and ordered the ad not to appear again in the form complained about.

The claims were absolute lowest-price promises, which require evidence ScotRail would always beat competitors' prices — not merely match them.

Its differentiators collapsed under scrutiny: some third-party retailers also charged no booking fee, and nothing showed ScotRail beat split-ticketing fares.

The price promise applied only to certain ticket types, so it could not substantiate an 'unbeatable' claim.

The overall impression discouraged consumers from comparison shopping — exactly the behaviour price competition depends on.

A 'lowest price' claim needs evidence you always beat competitors, not merely match them: dropping booking fees is not the same as being cheapest.

The ASA told Abellio ScotRail the ad must not appear again in the form complained about and not to claim the lowest available price unless it could prove it. ScotRail had already changed parts of its website wording. The ruling landed alongside related decisions in the ASA's rail-fare sweep, including the ban on Trainline's Best Price Guarantee ads.

FOLLOW THE EVIDENCE

The sources

  1. ASA Ruling on Abellio ScotRail Ltd t/a ScotRail asa.org.uk