Firstly £100 million is a very large sum of money to spend on advertising. Not only is it going to cost each taxpayer over £2 per head, it is close to the annual budget of the UK’s largest advertisers but will be spent over a maximum of 3 months.

Like all advertising, government advertising comes under the remit of OFCOM and the Advertising Standards Authority. Like all advertisers, the government must obey the ASA codes and rulings and it may be helpful to repeat items 3.1 and the start of item 3.2* from the rules: -

3.1 Advertisements must not materially mislead or be likely to do so

3.2 Advertisements must not mislead consumers by omitting material information. They must not, mislead by hiding material information of presenting it an unclear, unintelligible, ambiguous or untimely manner. Material information is information that consumers need in context to make informed decisions about whether to buy a product of service….

This is obviously not an issue for the Government Communications Service in creating a brief for agencies if the cabinet can be crystal clear on issues which will affect businesses and consumers on November 1st, it will be more difficult if the current somewhat clouded view of exactly what might happen continues.

Add to this that some advertisers occasionally find the ASA a little pernickety in interpreting the rules and are very open to relatively small numbers of consumer complaints creating decisions to review copy clearance. Not surprisingly many of the most successful and influential government campaigns such as drink dive, seatbelts and AIDs have occurred where clear legislation and public interest co-incide.

Possibly this year’s largest campaign may prove to an advertising agencies biggest headache.

*3.2 in the broadcast code, 3.3 in the non-broadcast code

Michael Cluff is a member of the CGE Executive and a senior media consultant with extensive experience of working with major advertisers and media companies around the world