Offsetting in the Crosshairs: Key Takeaways from the ASA’s Eurowings and Qatar Airways Decisions

On 15 July 2026, the Advertising Standards Authority (ASA) published two rulings concerning environmental claims made by airlines. Both decisions concerned advertising that suggested passengers could offset or compensate for the emissions associated with their flights through optional environmental programmes offered during the booking process. As with similar claims made previously by other airlines, the ASA found that these claims were likely to mislead consumers because they were not sufficiently substantiated. The rulings form part of a wider regulatory focus by the ASA on green claims in the aviation sector and confirm, yet again, that airlines seeking to advertise their environmental credentials need to exercise extreme caution.

The advertisements and the underlying offerings

Eurowings

The Eurowings decision concerned a paid-for Google advertisement stating that consumers could travel “climate-consciously” and in a “more eco-friendly” manner through the airline's “CO2-compensation” offering “by offsetting up to 100% of [the passenger’s] carbon emissions per flight”. 

The advert referred to Eurowings’ “PlanetBlu” scheme, under which passengers could pay an additional amount towards Sustainable Aviation Fuel (SAF) and climate protection projects. The amount payable was calculated by reference to the estimated emissions of the relevant flight.

Qatar Airways

The Qatar Airways decision concerned LinkedIn advertisements which promoted the airline's voluntary carbon offsetting programme for corporate customers. These included claims that the programme would allow passengers to “bulk offset the carbon emissions for your past and future flights” and to therefore “travel consciously by offsetting your flight’s carbon footprint”. 

According to Qatar Airways, the scheme was developed with the assistance of the International Air Transport Association (IATA) and used verified carbon units bought through the IATA Aviation Carbon Exchange (ACE). The units contributed to three Verra-certified renewable energy projects in Asia and Africa. Qatar Airways also argued that they used specific parameters (e.g., “business travellers” and “company size 250+”) to target their LinkedIn advertisements at an audience with a higher level of knowledge about carbon offsetting (i.e., senior businesspeople).

The advertising legal framework

The ASA is the UK’s independent advertising regulator. It enforces the UK advertising codes, investigates complaints, and monitors advertising across different media. Where it finds a breach, it can require an advertisement to be amended or withdrawn and prohibit similar claims unless they are adequately substantiated.

The airline rulings found breaches of the UK Code of Non-broadcast Advertising and Direct & Promotional Marketing (CAP Code), in particular:

• Rule 3.1 (Misleading advertising) – marketing communications must not materially mislead or be likely to mislead consumers.
• Rule 3.7 (Substantiation) – advertisers must hold documentary evidence to substantiate claims that consumers are likely to regard as objective.
• Rule 11.1 (Environmental claims) – the basis of environmental claims must be clear and must not omit material information.
• Rule 11.3 (Environmental claims) – absolute claims about environmental impact must be supported by a high level of evidence. If a product is advertised as “greener”, evidence must be provided to show the product’s benefit in comparison to its competitors. 

In severe cases, the ASA may also refer particular advertisements to Trading Standards and, ultimately, to the Competition and Markets Authority (the “CMA”) for further investigation. Given the increased consumer protection powers now available to the CMA under the Digital Markets Competition and Consumers Act 2024, which allows the CMA to issue financial penalties of up to 10% of global turnover for unfair commercial practices without first having to obtain a court order, this is a risk that should be taken seriously.

The ASA's reasoning

In both cases, the ASA focused on the overall impression conveyed to consumers rather than the detailed mechanics of the airlines' environmental programmes. The ASA considered that consumers would understand the advertisements to mean that the programmes could compensate for, or fully offset, the emissions from specific flights. 

The ASA acknowledged the evidence presented by the airlines and Qatar Airways’ attempts to target a more knowledgeable audience. Ultimately, however, neither factor was sufficient to substantiate the claims made. 

In particular, the ASA did not accept Qatar Airways’ argument that its advertisements had been limited to corporate travellers, instead finding that LinkedIn was available to everyone and that the advertisements were available to consumers too as a result.  In both cases, the ASA found that, although the evidence demonstrated the existence and operation of the relevant offsetting programme, it did not establish that flights would in fact be fully offset through the schemes. As such, the ASA considered the advertisements to be misleading.

In both cases, the ASA directed that the advertisements must not appear again in the form investigated and required the airlines not to make equivalent offsetting claims in future unless they held adequate substantiation. 

What do the rulings mean for airlines?

These decisions should not be viewed in isolation. Both rulings expressly state that they form part of a wider ASA project concerning carbon offsetting claims in the air travel sector.  They also build upon a growing body of ASA decisions involving airlines' environmental marketing and demonstrate the ASA’s willingness to take robust action against environmental claims that it considers to be insufficiently substantiated.

Most recently, in 2024 the ASA took action against Virgin Atlantic in respect of its “sustainable aviation fuel” advertising in relation to Flight 100 (promoted as the first transatlantic flight using 100% SAF). Before that, in 2023, the ASA upheld complaints against Etihad Airways, Lufthansa and Air France in relation to claims made by those airlines emphasising their “environmental advocacy” and encouraging passengers to “fly more sustainably” and “travel better and sustainably” by flying with them.  In 2020, the ASA also required Ryanair to remove certain environmental claims regarding the airline’s emissions.  In each of these cases, the ASA considered that consumers would understand the advertising as communicating broader environmental benefits than could be substantiated. 

Notably, in this case, both the Eurowings and Qatar Airways’ advertisements were identified through the ASA's Active Ad Monitoring system. This approach, which was also used in respect of the Etihad, Lufthansa and Air France advertisements in 2023, uses artificial intelligence to proactively search for online advertisements that may breach the relevant advertising rules. The continued use of these tools demonstrates that the ASA’s enforcement activity is no longer solely complaint-driven. Instead, it is increasingly using technology-assisted monitoring to identify potentially non-compliant advertising proactively and target enforcement activity accordingly.

What next?

Taken together, the rulings against Eurowings and Qatar Airways should be taken by airlines as a clear reminder that the ASA will not tolerate unsubstantiated environmental claims. Although airlines can continue to advertise their environmental initiatives, including carbon offsetting schemes, they must ensure that any such claims are well supported by relevant, contemporary and easily understood evidence and are articulated in a manner that is unlikely to mislead consumers. 

This article was written by Patrick Bettle and Beata Kolodziej.

If you would like any further information on these decisions or advice on greenwashing concerns affecting your organisation, please contact Chloe Challinor, Patrick Bettle, Beata Kolodziej or your usual contact in the Burges Salmon aviation team.