The directors present their annual report and financial statements for the year ended 31 December 2024.
The directors who held office during the year and up to the date of signature of the financial statements were as follows:
Council and Committees structure
The ASA is governed by two Councils: broadcast and non-broadcast. There are twelve members, excluding the Chair, and all sit on both bodies. Two-thirds are independent of industry and the remaining members have a recent or current knowledge of the advertiser, agency or media sectors. Members are appointed through an open recruitment process, with all positions advertised. The members have a wide range of skills and experiences, with representation of all four nations of the UK.
Between 1 January 2024 and 31 December 2024, the members of the Council were:
Industry members | Non-industry members |
Zaid Al-Qassab (resigned 26 April 2024) | Aaqil Ahmed (resigned 26 April 2024) |
Matt Barwell (appointed 26 April 2024) | Murphy Cobbing (appointed 26 April 2024) |
Claire Hilton | Elizabeth Gordon |
Mark Howe | Alison Hastings |
Kirsten Miller | Rotha Johnston |
| Richard Lloyd |
| Dr Rebecca Rumbul |
| Krystle Sargent |
| Monisha Shah (appointed 26 April 2024) |
| Nita Woods (resigned 26 April 2024) |
Baroness Morgan of Cotes succeeded Lord Currie of Marylebone as Chair on 1 November 2024.
The Council operates as the Board of the ASA. It meets monthly, with a Board meeting devoted to corporate governance issues and a Casework meeting largely concerned with casework and proactive project decisions and related policy matters.
Governance arrangements
The ASA Chair is appointed by the Advertising Standards Board of Finance following an open recruitment process. The 12 members of Council are also appointed following an open process led by the Chair. Council members serve a maximum of two three-year terms.
Following a period of successful succession planning, Baroness Morgan of Cotes was appointed as Chair in June 2024, officially commencing on 1 November 2024 and replacing Lord Currie of Marylebone who reached the end of his term on 31 October 2024. Three new Council members were also appointed in 2024 due to three members reaching the end of their second three-year term.
In addition to its decision-maker responsibilities in administering the non-broadcast and broadcast Advertising Codes, the ASA Council is responsible for setting strategy and overseeing its delivery. During 2024, it oversaw the delivery of the first year of the ASA’s 2024-2028 strategy by ensuring the organisation’s activity remained aligned to purpose, that systems and processes were effective, and that the Senior Management Team were held to account for the day-to-day operation of the ASA’s activity.
The six strands of the 2024-2028 organisational strategy are:
People: We will put people first and prioritise protecting vulnerable people. On matters of offence, we will prioritise only the most serious cases. We will take account of prevailing societal trends and beliefs to inform our regulation and ensure we represent everyone. And we will make sure we have the best people, recruiting, retaining and exploring more flexible working practices for people from both diverse backgrounds and a wider geographical area.
Planet: We will run our Climate change and the environment project throughout the strategy period, as well as continuing to implement our own Net Zero plan.
Online: We will continue to regulate all forms of online advertising that we cover, using our AI-based Active Ad Monitoring system to identify and swiftly act against irresponsible online ads, as well as provide more comprehensive reporting on compliance levels. We will champion how we think the regulatory framework should develop to help meet the challenges we face regulating online ads, bringing greater transparency and broader accountability. We will work closely with other statutory regulators whose remits overlap with ours and play our part in tackling fraud involving online ads. And we will be authoritative and influential in online ad regulation.
Awareness and buy-in: We will be ambitious in increasing public and opinion-former awareness of, and trust in, the nature and extent of our ad regulation in all media. We will continue to make the case for collective ad regulation to the ad industry. And we will continue to invest in our data science capability, more people to address over-leanness in some areas and more people to act on data science insights.
Collective ad regulation: We will continue to work with governments and statutory regulators, including to explore and as necessary address any material gaps in ad regulation. And we will, through our membership of EASA and ICAS, continue our engagement with supranational organisations and institutions.
Operational transformation: We will prioritise proactive regulatory projects that adopt a ‘whole system’ approach on ad-related issues that cause the most detriment to people. We will resolve investigations quicker. And we will fully exploit data science, deploying mature capability and securing access to more ads and better data about them.
Council meeting attendance in 2024 | Jan | Feb | Mar | Apr | May | Jun | Jul | Sep | Oct | Nov | Dec |
Lord Currie of Marylebone (Chair) | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | n/a | n/a |
Baroness Morgan of Cotes (Chair) | n/a | n/a | n/a | n/a | n/a | n/a | n/a | ✔ | ✔ | ✔ | ✔ |
Aaqil Ahmed | ✔ | X | ✔ | ✔ | n/a | n/a | n/a | n/a | n/a | n/a | n/a |
Zaid Al-Qassab | ✔ | ✔ | ✔ | ✔ | n/a | n/a | n/a | n/a | n/a | n/a | n/a |
Matt Barwell | n/a | n/a | n/a | ✔ | ✔ | ✔ | ✔ | X | ✔ | ✔ | ✔ |
Murphy Cobbing | n/a | n/a | n/a | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ |
Claire Hilton | ✔ | ✔ | ✔ | X | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ |
Elizabeth Gordon | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ |
Alison Hastings | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ |
Mark Howe | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ |
Rotha Johnston | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ |
Richard Lloyd | ✔ | ✔ | ✔ | ✔ | X | ✔ | X | ✔ | ✔ | ✔ | X |
Kirsten Miller | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | X | ✔ | ✔ |
Dr Rebecca Rumbul | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ |
Krystle Sargent | ✔ | ✔ | ✔ | X | ✔ | ✔ | ✔ | ✔ | ✔ | X | ✔ |
Monisha Shah | n/a | n/a | n/a | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ | ✔ |
Nita Woods | ✔ | ✔ | ✔ | ✔ | n/a | n/a | n/a | n/a | n/a | n/a | n/a |
Sub-committees
The Council is supported by three committees whose role is to closely monitor organisational performance and people, finance and risk matters. The committee chairs provide an update to the Council after each committee meeting.
Appointments, Remuneration and People Committee
The purpose of the Appointments, Remuneration and People Committee is to oversee organisation-level people-related issues, including the development and delivery of the People Strategy. The Committee also reviews the results of the ASA employee surveys and management’s response and considers updates from the Equality, Diversity and Inclusion Working Group. It also receives reports from the Chair and Chief Executive on Chief Executive, Directors and staff remuneration and periodically reviews Council member remuneration. The committee comprises a minimum of three Council members and the ASA.
Appointments, Remuneration and People Committee meeting attendance | g | Feb | Sep |
Lord Currie of Marylebone (Chair) |
| ✔ | ✔ |
Baroness Morgan of Cotes (Chair) |
| n/a | ✔ |
Claire Hilton |
| ✔ | ✔ |
Elizabeth Gordon |
| n/a | ✔ |
Alison Hastings |
| ✔ | X |
Richard Lloyd |
| ✔ | ✔ |
Krystle Sargent |
| ✔ | ✔ |
Risk and Audit Committee
The purpose of the Risk and Audit Committee is to examine the ASA’s revenues and costs and advise on areas such as business continuity and risk management. It also monitors the ASA’s internal controls and financial reporting. Any significant findings or identified weaknesses are closely examined so that appropriate action can be taken, monitored, and reported to the Board. The Committee also reviews the draft financial statements and post-audit findings before their presentation to the Board and advises the Board on the appointment of external auditors.
During the year the Committee carried out a deep-dive into the risks of recruiting into hard to fill roles, and the risks associated with our ongoing move to a ‘whole system’ approach to regulatory projects.
The Risk and Audit Committee comprises a minimum three council members, one of whom is Chair, plus the ASA Chair. The committee meets not less than three times a year.
Risk and Audit Committee meeting attendance | g | Mar | Jun | Sep |
Aaqil Ahmed |
| ✔ | n/a | n/a |
Zaid Al-Qassab |
| ✔ | n/a | n/a |
Mark Howe |
| n/a | ✔ | X |
Rotha Johnston |
| n/a | ✔ | ✔ |
Richard Lloyd |
| ✔ | ✔ | ✔ |
Kirsten Miller |
| ✔ | ✔ | ✔ |
Dr Rebecca Rumbul |
| n/a | ✔ | ✔ |
Nita Woods |
| ✔ | n/a | n/a |
Performance Review Committee
The purpose of the Performance Review Committee is to review the ASA’s full and half year performance reports on behalf of Council. It comprises a minimum three council members, one of whom is Chair, plus the ASA Chair. The committee meets not less than twice a year.
All meetings held in 2024 were quorate.
Performance Review Committee meeting attendance | g | Mar | Aug |
Zaid Al-Qassab |
| ✔ | n/a |
Elizabeth Gordon |
| n/a | ✔ |
Alison Hastings |
| n/a | X |
Rotha Johnston |
| ✔ | X |
Kirsten Miller |
| ✔ | ✔ |
Dr Rebecca Rumbul |
| ✔ | X |
Krystle Sargent |
| ✔ | X |
Governance Review
During 2024, Council agreed to carry out an internal review of the ASA’s governance arrangements. It was not intended to be a full, external evaluation of board effectiveness, but to provide the Council and its incoming chair with an assessment of current practices and practical proposals for possible adjustments, including feedback from non-executives and executives.
The review found that the ASA’s governance arrangements are both compliant with relevant standards and felt to be highly effective by non-executive directors and senior executives alike. The system of committees with delegated responsibility to scrutinise the organisation’s performance, risk, finances and people strategy is effective and in line with good practice. An Equality, Diversity and Inclusion Working Group has been effective in ensuring the ASA has senior focus on this important dimension of organisational strategy. Reporting back to the Council by committee chairs is timely and effective, and key strategic items such as the risk register and performance reporting are given additional time at the full Board.
Opportunities to improve transparency reporting, processes to support the effectiveness or performance of board members and board programming were identified and the recommendations will be implemented over a 12–18-month period.
Oversight of strategic risks
Oversight of strategic risks is delegated by Council to the Risk and Audit Committee which reviews the organisational risk register twice a year.
The most significant risks at the end of the financial year related to:
Insufficient funding (cyclical or structural); mitigation for which includes making a compelling case for contribution to and investment in the ASA system by advertisers and digital platforms; and robust financial contingency plans.
Ineffective regulation of scam ads and/or website and social media claims; mitigation for which includes collaborative working with government and other regulators and better use of technology
Statutory regulation of online paid and/or sensitive sector ads; mitigated by demonstrating and communicating our effectiveness and working collaboratively with other regulatory bodies
Unduly prohibitive approach to regulating environmental ads; for which mitigation includes the creation of a ‘Green Team’
Cybersecurity and data protection; mitigated by continued adherence to NCSC guidance, external audit and maintaining CyberEssentials+ accreditation
JR loss; mitigated by continued investment in legal and management resource
Remuneration
Council member remuneration
Council members receive remuneration of £20,000 per annum for an average time commitment of three days per month. A supplement of £500 is paid to members based outside London and the home counties. Remuneration is reviewed every three years with consideration of available benchmarks. Council remuneration was last reviewed in April 2024.
The Chair receives remuneration of £137,760 for an average time commitment of 14 hours per week. The Chair’s remuneration is set by the Advertising Standards Board of Finance which operates at arm’s length from the Advertising Standards Authority.
Staff remuneration
The ASA’s remuneration policy is developed by the Director of Corporate Services in conjunction with the Chief Executive and Senior Management Team and is designed to support our strategic objective to attract and retain the best talent whist upholding principles of fairness, transparency and sustainability. All roles are periodically benchmarked against comparable roles in the regulation sector and, as appropriate, beyond. This exercise, alongside a comprehensive job evaluation exercise and review of the organisation’s benefits package, was last begun in 2024 and is due for completion in early 2025.
Annual pay awards, which comprise a cost of living and individual performance award element, are agreed by the Senior Management Team on the recommendation of the Director of Corporate Services. An average 5% total award was made in 2024.
Staff are also eligible for a core benefits package comprising life assurance, income protection and private medical insurance and an employer’s pension contribution of up to 7% (Senior Management Team 15%) according to the level of employee contribution.
Chief Executive and Directors remuneration
Chief Executive and Directors’ remuneration is set in the same way as staff pay. These roles are also eligible for a non-consolidated performance bonus of up to 10%, awarded on the basis of individual and organisational performance.
Pay multiples
The table below discloses the relationship between the total remuneration of the highest-paid director against the 25th percentile, median and 75th percentile of remuneration of our workforce. The middle of the banded remuneration of the highest-paid director has been used for the ratio calculation.
2023 | 25th percentile | Median | 75th percentile |
Salary component of total remuneration (£) | £28,595 | £41,544 | £50,443 |
Ratio (against highest paid director) | 7.2 | 4.96 | 4.08 |
Gender and ethnicity pay gap
We voluntarily report our gender and ethnicity pay gaps on our website (www.asa.org.uk).
Our latest median gender pay gap (2023) was 10.7% and the mean gender pay gap was 18.3%, both in favour of male employees. The median gender bonus gap for 2023 was 7.8% and the mean gender bonus gap is 37.2% (both in favour of male employees).
Our latest median ethnicity pay gap (2023) was 0.3% in favour of white employees and our mean pay gap is 5.7% in favour of ethnic minority employees. The median bonus gap was 2.6% in favour of white employees and our mean bonus gap is 12.3% in favour of ethnic minority employees.
A detailed analysis of the company's activity, performance and future plans is contained within the ASA and CAP annual report, which can be found at www.asa.org.uk.
The auditor, Moore Kingston Smith LLP, is deemed to be reappointed under section 487(2) of the Companies Act 2006.
This report has been prepared in accordance with the provisions applicable to companies entitled to the small companies exemption.
We have audited the financial statements of The Advertising Standards Authority (Broadcast) Limited (the 'company') for the year ended 31 December 2024 which comprise the Statement of Income and Retained Earnings, the Balance Sheet and notes to the financial statements, including significant accounting policies. The financial reporting framework that has been applied in their preparation is applicable law and United Kingdom Accounting Standards, including FRS 102 The Financial Reporting Standard applicable in the UK and Republic of Ireland (United Kingdom Generally Accepted Accounting Practice).
Basis for opinion
Conclusions relating to going concern
In auditing the financial statements, we have concluded that the directors' use of the going concern basis of accounting in the preparation of the financial statements is appropriate.
Based on the work we have performed, we have not identified any material uncertainties relating to events or conditions that, individually or collectively, may cast significant doubt on the company's ability to continue as a going concern for a period of at least twelve months from when the financial statements are authorised for issue.
Our responsibilities and the responsibilities of the directors with respect to going concern are described in the relevant sections of this report.
Other information
Opinions on other matters prescribed by the Companies Act 2006
In our opinion, based on the work undertaken in the course of our audit:
the information given in the Directors' Report for the financial year for which the financial statements are prepared is consistent with the financial statements; and
the Directors' Report has been prepared in accordance with applicable legal requirements.
Explanation as to what extent the audit was considered capable of detecting irregularities, including fraud
Irregularities, including fraud, are instances of non-compliance with laws and regulations. We design procedures in line with our responsibilities, outlined above, to detect material misstatements in respect of irregularities, including fraud. The extent to which our procedures are capable of detecting irregularities, including fraud is detailed below.
The objectives of our audit in respect of fraud, are; to identify and assess the risks of material misstatement of the financial statements due to fraud; to obtain sufficient appropriate audit evidence regarding the assessed risks of material misstatement due to fraud, through designing and implementing appropriate responses to those assessed risks; and to respond appropriately to instances of fraud or suspected fraud identified during the audit. However, the primary responsibility for the prevention and detection of fraud rests with both management and those charged with governance of the company.
Our approach was as follows:
We obtained an understanding of the legal and regulatory requirements applicable to the company and considered that the most significant are the Companies Act 2006, UK financial reporting standards as issued by the Financial Reporting Council, and UK taxation legislation.
We obtained an understanding of how the company complies with these requirements by discussions with management and those charged with governance.
We assessed the risk of material misstatement of the financial statements, including the risk of material misstatement due to fraud and how it might occur, by holding discussions with management and those charged with governance.
We inquired of management and those charged with governance as to any known instances of non-compliance or suspected non-compliance with laws and regulations.
Based on this understanding, we designed specific appropriate audit procedures to identify instances of non-compliance with laws and regulations. This included making enquiries of management and those charged with governance and obtaining additional corroborative evidence as required.
There are inherent limitations in the audit procedures described above. We are less likely to become aware of instances of non-compliance with laws and regulations that are not closely related to events and transactions reflected in the financial statements. Also, the risk of not detecting a material misstatement due to fraud is higher than the risk of not detecting one resulting from error, as fraud may involve deliberate concealment by, for example, forgery or intentional misrepresentations, or through collusion.
Use of our report
This report is made solely to the company's members, as a body, in accordance with Chapter 3 of Part 16 of the Companies Act 2006. Our audit work has been undertaken so that we might state to the company's members those matters we are required to state to them in an auditor's report and for no other purpose. To the fullest extent permitted by law, we do not accept or assume responsibility to anyone other than the company and the company's members as a body, for our audit work, for this report, or for the opinions we have formed.
The Advertising Standards Authority (Broadcast) Limited is a private company limited by guarantee incorporated in England and Wales. The registered office is Castle House, Paul Street, London, England, EC2A 4LS.
The financial statements are prepared in sterling, which is the functional currency of the company. Monetary amounts in these financial statements are rounded to the nearest £.
Cash received from BASBOF is credited to the profit an loss account in accordance with the amounts agreed with them for the financial year.
All expenditure is recognised on a accruals basis.
The carrying values of tangible fixed assets are reviewed for impairment when events or changes in circumstances indicate the carrying value may not be recoverable.
The tax expense represents the sum of the tax currently payable and deferred tax/
Current tax
The tax currently payable is based on taxable profit for the year. Taxable profit differs from net profit as reported in the profit and loss account because it excludes items of income or expense that are taxable or deductible in other years and it further excludes items that are never taxable or deductible. The company’s liability for current tax is calculated using tax rates that have been enacted or substantively enacted by the reporting end date.
Deferred tax
Deferred tax liabilities are generally recognised for all timing differences and deferred tax assets are recognised to the extent that it is probable that they will be recovered against the reversal of deferred tax liabilities or other future taxable profits. Such assets and liabilities are not recognised if the timing difference arises from goodwill or from the initial recognition of other assets and liabilities in a transaction that affects neither the tax profit nor the accounting profit.
In the application of the company’s accounting policies, the directors are required to make judgements, estimates and assumptions about the carrying amount of assets and liabilities that are not readily apparent from other sources. The estimates and associated assumptions are based on historical experience and other factors that are considered to be relevant. Actual results may differ from these estimates.
The estimates and underlying assumptions are reviewed on an ongoing basis. Revisions to accounting estimates are recognised in the period in which the estimate is revised where the revision affects only that period, or in the period of the revision and future periods where the revision affects both current and future periods.
The following judgements (apart from those involving estimates) have had the most significant effect on amounts recognised in the financial statements.
Cash received from ASBOF has been recognised as revenue within the accounts as opposed to grant income. The money has been received in exchange for the service of a regulator and there are no conditions linked to how the money being transferred should be spent.
The total turnover of the company for the year has been derived from its principal activity wholly undertaken in the England and Wales.
The average monthly number of persons (including Council members and Directors) employed jointly by the company and The Advertising Standards Authority Limited during the year was:
Their aggregate remuneration comprised:
The total emoluments and fees paid to the Council members, including the Chairman, were £152,088 (2023 - £137,962). The emoluments (including benefits) in respect of the Chairman, being the highest paid director, were £57,528 (2023 - £54,676) and £nil (2023 - £nil) to defined contribution pension schemes. Council members, other than the Chairman, were remunerated from £5,534 to £7,140 per annum.
In 2013 the company introduced a flexible benefit scheme and changed the pension scheme to a Group Personal Pension Plan with Aegon. The company's contributions to this scheme are fixed at a maximum of 7% of pensionable salary for staff (15% for senior management). Members' contributions are variable. The company does not owe anything (2023: £nil) at the year end.
The company is limited by guarantee, not having a share capital and consequently the liability of members is limited, subject to an undertaking by each member to contribute to the net assets or liabilities of the company on winding up such amounts as may be required not exceeding £1.
At the reporting end date the company had outstanding commitments for future minimum lease payments under non-cancellable operating leases, as follows:
During the year the company was charged £3,700,625 (2023: £3,269,980) by The Advertising Standards Authority Limited (ASA) a company under common control, for shared costs which were apportioned on staff headcount and workload.
At the balance sheet date, the amount due to the ASA was £159,782 (2023: due from £48,480).