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BCAP Payday Loan Consultation

Following both its call for evidence and content review on payday loan and other high-cost-short-term credit (HCSTC) advertising, BCAP is now consulting on whether to introduce TV scheduling restrictions for HCSTC ads using the 120 index, similar to the restrictions in place for alcohol, gambling and e-cigarette ads. The consultation will close at 5pm on Friday 11 December 2015.


IPA Director of Legal & Public Affairs, Richard Lindsay, says, "As the HCSTC sector has grown, so too have concerns about the impact of HCSTC loans on the vulnerable, particularly children. There have been calls for new scheduling restrictions, including a ban on HCSTC ads appearing around TV programmes aimed at children - as with alcohol, gambling and e-cigarettes - and a 9pm TV watershed ban.  A pre-9pm restriction would be severe, banning all relevant advertising before 9pm, even around programmes with an adult audience, and would ignore the fact that children do watch television later in the evenings. A restriction using the 120 index would aim to restrict children from seeing HCSTC ads, regardless of the time of day."  

View the full BCAP statement below:

BCAP payday loans consultation

Following on from our content review, we are today launching a consultation on whether it is proportionate and necessary to introduce scheduling restrictions on the television advertising of high-cost short-term credit (HCSTC), a category which is commonly referred to as payday loans. We consider that a public consultation is necessary to satisfy us, in relation to both our own regulatory objectives and societal expectations, that we have considered all relevant information that might support a scheduling restriction.

Our call for evidence found little robust evidence of advertising-related harm, but the information provided by respondents has been invaluable in identifying issues that relate to the potential effect of HCSTC advertising. We believe that there are gaps and inadequacies in the evidence base we have seen; particularly, that the precise harm that a scheduling restriction might help to prevent has not been articulated. Further, we consider that, at the time of publication, it is unclear whether the additional limitations on advertisers’ rights to reach a legitimate adult audience and those adults’ rights to receive ads for HCSTC, as well as the potential financial impact on broadcasters that would derive from scheduling restrictions, are proportionate to our stated policy objectives of rules that are transparent, accountable, consistent and targeted only where regulation is needed. However, the information that has been provided will enable the preliminary research carried out to date to be continued with a focus on addressing these gaps.

We have also provided an assessment of the potential economic impact of restrictions on broadcasters and potential redistribution of HCSTC ads throughout the television schedule; we are obliged to consider such information in determining the proportionality of any restriction. Overall, scheduling restrictions based on either a 4-15 or 10-15 index would not be likely have a significant effect on the number of impacts in commercial airtime, so their removal would not be likely to cause significant revenue loss to broadcasters. Furthermore, the majority of any loss that might occur would be likely to be mitigated by broadcasters.

We invite respondents to answer questions on whether scheduling restrictions are justified and the evidential grounds that might support their introduction.

The consultation will close at 5pm Wednesday 16 December.

Read the full consultation and evidence submissions

Last updated 07/10/2015

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