Competitive claim substantiation for F2P genre ads
Operator checklist for #1 / better-than claims in F2P ads, grounded in FTC substantiation guidance and ASA CAP advice on No.1 and comparisons.
“#1 SLG” and “better than X” lines are cheap to write and expensive to defend. This checklist maps US FTC substantiation basics and UK ASA/CAP advice onto a pre-flight file for F2P genre ads. It is not legal advice.
What the primary pages say
The FTC’s Advertising FAQ’s for small business states that advertisers must have a “reasonable basis” — objective evidence — before an ad runs, and that the kind of evidence depends on the claim. ASA CAP’s “No. 1” advice (updated 11 April 2025) says unqualified number-one claims are usually read like best-selling or leading claims and need documentary evidence under CAP Code rule 3.7. Comparisons: General covers identifiable competitor comparisons and the need for a clear basis.
Operator checklist
| Step | Pass criterion | Fail / hold |
|---|---|---|
| 1. Claim inventory | Every objective superiority, parity or “#1” line listed with geo and placement | Claim only in the video VO, absent from the brief |
| 2. Consumer reading | Intended meaning written in plain language (downloads, revenue, rating, genre niche) | Ambiguous “#1” with no metric |
| 3. Evidence on file before flight | Dated dataset or audit covering the claimed market, period and metric | Evidence promised “after launch” |
| 4. Like-for-like | Compared titles meet the same need / purpose for identifiable comparisons | Cross-genre “better than” without basis |
| 5. Qualification on creative | Any limit (geo, time window, store, genre) appears where the claim appears | Footnote only on landing page |
| 6. Expiry | Review date when the ranking or survey ages out | Evergreen #1 with 18-month-old chart |
| 7. Observation vs inference | File stores source URL and extract date | Vendor sales deck paraphrased without the underlying table |
Facts versus limits
| Field | Evidence |
|---|---|
| FTC reasonable-basis rule | Advertising FAQ’s (accessed 2026-09-20) |
| ASA No.1 reading | CAP AdviceOnline 11 Apr 2025 |
| Jurisdiction coverage | US + UK guidance cited; other markets not surveyed here |
| Named F2P ruling | Not claimed here |
Download the checklist CSV.
This is not legal advice.
