The Advertising Board ("Board") has published the Advertising Board 2024 Annual Report ("Report") on February 6, 2025. The Report compiles key decisions issued by the Board throughout 2024, oversight activities conducted, and sectoral evaluations, presenting them to the public. The section titled “Key Topics in Advertising Board Decisions” provides an examination of the Board’s activities under headings such as greenwashing and environmental claims, dark commercial patterns, manipulative results, unauthorized memberships, transferred personal data, false reviews, fraudulent ratings, shadow pricing, misleading discounts, and prohibited advertisements.
A- Greenwashing and Unsubstantiated Environmental Claims
Studies conducted within the European Union have demonstrated that commercial communications creating the impression that a product or service has a positive environmental impact, has no adverse environmental effect, or is less harmful to the environment compared to competitors pose a risk of misleading consumers. In this context, deceptive environmental claims were a prominent issue on the Board’s agenda in 2024. The Board’s review of environmental claim-based advertisements identified misleading statements and a lack of substantiating information.
For instance, in the ready-to-wear sector, a brand used claims such as "We pledge to the Earth" and "We commit to making all our packaging 100% sustainable by 2024." However, it was found that no information was provided on which product or product group these statements applied to. Similarly, no accredited scientific report was presented to substantiate the "Zero waste, zero emissions" claim, resulting in administrative sanctions against the advertiser. Likewise, advertisements in the food, apparel, and durable goods sectors were sanctioned for using vague and unsubstantiated environmental claims such as “eco-friendly” and “climate-friendly”. Additionally, in the technology sector, a sustainability certificate was found not to be verified by an accredited institution, with no scientific basis provided, raising concerns about misleading consumers. Similarly, advertisements containing carbon footprint reduction or eco-friendly production processes were determined to lack tangible evidence and instead relied on ambiguous or exaggerated statements.
B- Dark Commercial Patterns and Manipulative Practices
Dark commercial patterns refer to manipulative designs that interfere with consumers’ autonomous decision-making processes, deceiving and misleading them. Such practices were classified as “unfair commercial practices” under the Regulation on Commercial Advertising and Unfair Commercial Practices in 2022.
Following ex officio investigations initiated by the Ministry, certain subscription-based service practices were found to be deceptive and misleading. These included:
- Pre-selected subscription packages,
- Interface manipulations that encourage users to accept updated membership terms,
- Designs that push consumers toward more expensive packages,
- Claims of popularity without transparent criteria, and
- Automatic renewal of subscriptions after a free trial period by collecting payment details upfront.
These manipulative practices were found to adversely affect consumer decision-making, leading to administrative sanctions against the responsible companies.
Additionally, failure to provide a clear "Decline" option for subscription updates or offers, highlighting certain options to steer consumer choices, and making subscription cancellations difficult were deemed unfair commercial practices. The Board emphasized that consumers must be able to freely exercise their choices and that both acceptance and rejection options must be presented under equal conditions. The Board also announced that sectoral reviews of manipulative designs would continue.
C- Unauthorized Memberships and Transfer of Personal Data
A study conducted under the Digital Consumer Protection Project revealed that while half of consumers are concerned about sharing their personal data, seven out of ten consumers tend to accept “mandatory” membership and electronic communication approvals as part of online transactions.
Based on these findings, the Board investigated e-commerce platforms imposing mandatory memberships, assessing whether:
- Consumers were asked for more personal data than necessary,
- The membership cancellation process was more complex than the sign-up process, and
- Personal data was shared with third parties for marketing and targeted advertising purposes.
The review identified platforms where consumers were forced to register to complete a purchase, and membership agreements included provisions allowing the use of personal data for profiling and advertising purposes. This practice was determined to be a form of dark commercial pattern that compels consumers to share their personal data indirectly, leading to administrative sanctions.
D- False Reviews, Fraudulent Ratings, and Manipulated Scores
The Digital Consumer Protection Project also found that reviews and ratings significantly influence consumers' purchasing decisions. Therefore, the reliability of review and ranking mechanisms, ensuring that evaluations are made only by those who have actually purchased the product or service, is crucial.
However, investigations revealed deceptive practices, including:
- Fake AI-generated reviews,
- Fabricated reviews from individuals with no real experience of the product or service, and
- The purchase of consumer reviews to create false impressions.
For example, an investigation uncovered that hotel service reviews from one website were transferred and published on another website owned by the same entity, where consumers could leave reviews without making a purchase. Additionally, certain platforms failed to provide transparent information on ranking algorithms, resulting in sanctions for deceptive commercial practices.
E- Shadow Pricing and Misleading Discounts
The most frequent topic on the Board’s 2024 agenda was discounted sales advertisements. With the expansion of online shopping channels, discount campaigns have become more frequent and diverse, leading to an increase in consumer complaints.
The Board found that some campaigns created a false perception of continuous discounts, causing consumer confusion. For example, in one case, an advertiser promoted a six-month-long "seasonal discount" campaign covering three different seasons (winter, spring, and summer) with constantly changing products, resulting in a misleading perception of permanent discounts. Such campaigns were deemed deceptive, and the Board ordered their suspension.
F- Prohibited Advertisements
Under the Regulation on Commercial Advertising and Unfair Commercial Practices, advertisements for fortune tellers, psychics, astrologers, and illegal gambling and betting services are strictly prohibited. However, despite this ban, numerous advertisers and media platforms violated this regulation in 2024, leading to sanctions.
The Board specifically targeted advertisements that:
- Encouraged or condoned unlawful or unethical behavior,
- Exploited religious beliefs, and
- Manipulated consumers’ fears and superstitions.
Conclusion
Throughout 2024, the Advertising Board rigorously monitored deceptive and misleading commercial practices, ensuring compliance with advertising regulations across various industries. By focusing on issues such as greenwashing, dark commercial patterns, unauthorized memberships, misleading pricing, and prohibited advertisements, the Board reinforced consumer rights and fair market conditions. Moving forward, the Board remains committed to strengthening oversight, promoting transparent and ethical advertising practices, and protecting consumers from manipulative commercial strategies.