By John Donovan
A Shell advertising campaign designed to showcase renewable electricity, offshore wind and electric-vehicle charging was banned by Britain’s advertising watchdog after it concluded that the advertisements omitted information consumers needed in order to understand the true balance of Shell’s business.
Campaign reported the ruling under the admirably direct headline “ASA bans three Shell ads for greenwashing.” The campaign had been created by WPP agency Wunderman Thompson UK. The Campaign report was published on 8 June 2023, following the Advertising Standards Authority’s ruling the previous day. (Campaign Asia)
Three years later, Shell’s own latest annual reporting makes the ruling worth revisiting.
“The UK is READY for Cleaner Energy”
The case concerned three advertisements: a Bristol poster, a television advertisement and a YouTube video.
The Bristol poster proclaimed:
“BRISTOL is READY for Cleaner Energy”
and stated that 78,000 homes in South-West England used renewable electricity from Shell Energy.
The television and YouTube advertisements went considerably further. They told viewers that 1.4 million UK households used renewable electricity from Shell, referred to a wind project potentially capable of powering six million homes and highlighted Shell’s plans for tens of thousands of electric-vehicle charging points.
They concluded with:
“The UK is READY for Cleaner Energy”
and Shell’s #PoweringProgress branding. (ASA)
None of those individual activities was invented.
That was not the ASA’s objection.
The problem was what the advertisements left out.
The missing part of the picture
Adfree Cities complained that the advertising presented Shell’s lower-carbon activities without properly explaining the enormous continuing role of oil and gas in Shell’s business.
The ASA agreed.
Its reasoning is significant because it went beyond asking whether the individual statements in an advertisement were literally accurate. The regulator considered the overall impression created for an ordinary consumer.
The ASA concluded that the cumulative effect of Shell’s claims could give viewers the impression that lower-carbon energy already represented a significant proportion of the products in which Shell invested and which it sold — or would do so in the near future. (ASA)
Against that impression stood a rather substantial omitted fact.
The ASA said that:
“large-scale oil and gas investment and extraction comprised the vast majority of the company’s business model in 2022”
and would continue to do so in the near future. (ASA)
That information, the watchdog decided, was material.
Without it, the advertisements were likely to mislead.
The complaint on that issue was therefore upheld and the advertisements were ordered not to appear again in the same form. The separate complaint concerning whether Shell could substantiate the renewable-electricity customer figures was not upheld. (ASA)
That distinction is important.
The ASA did not rule that everything Shell said about renewable power, wind farms or EV charging was false.
It ruled, in effect, that selectively presenting those activities without adequate information about the much larger fossil-fuel business created a misleading picture.
That is a rather more sophisticated form of greenwashing than simply making a false statement.
Shell strongly disagreed
Shell rejected the ASA’s reasoning.
The company argued that consumers already knew perfectly well that Shell produced and sold oil and gas. Its advertising was intended to make people aware of the lower-emission alternatives Shell was also developing.
Shell even suggested that the ASA decision could slow the UK’s transition towards renewable energy. (STV News)
There was an obvious tension between the two positions.
Shell essentially argued:
Everybody knows we are an oil and gas company, so why should every advertisement about cleaner products have to remind them?
The ASA’s response was that consumers might know Shell was involved in oil and gas without appreciating the relative scale of the green activities being promoted compared with the rest of Shell’s business.
That distinction became the heart of the ruling.
Now look at Shell’s own 2025 figures
This is where Shell’s latest Annual Report and Accounts 2025, published on 12 March 2026, becomes particularly interesting. (Shell)
Shell reports total cash capital expenditure of $20.9 billion in 2025.
Its own breakdown is:
- $12.3 billion — Oil, oil products and other
- $4.6 billion — LNG, gas and power marketing and trading
- $2.0 billion — Low-carbon energy solutions
- $2.0 billion — Non-energy products (Shell)
The low-carbon category therefore represented roughly 9.6% of Shell’s total cash capital expenditure in 2025.
That does not mean that every dollar in Shell’s other categories can simply be labelled fossil-fuel expenditure — Shell’s “LNG, gas and power marketing and trading” category, for example, combines several activities.
But the figures unquestionably provide the sort of proportional context that the ASA found missing from the 2022 advertising campaign.
Shell’s EU Taxonomy disclosures produce an even more striking measure, although they are calculated on a different basis and should not be confused with Shell’s cash-capital-expenditure categories.
For 2025, Shell reported taxonomy-eligible capital expenditure of 10.9% and taxonomy-aligned capital expenditure of 4.6%, down from 6.0% aligned capex in 2024. Shell explains that the decline principally reflected its decision to stop construction of its Rotterdam biofuels plant, reduced investment in low-carbon road transport and completion of construction on certain wind and solar assets. (Shell)
Those numbers do not prove that Shell is doing nothing about the energy transition.
They do, however, demonstrate why percentages, proportions and definitions matter when a global hydrocarbon company advertises selected green investments to the public.
Shell appears to have learned the advertising lesson
There is another development which deserves to be recorded in fairness to Shell.
In April 2025, the ASA considered another Shell television advertisement after receiving 75 complaints, including complaints from Adfree Cities and Carbon Tracker.
This time, the regulator did not uphold the complaint.
Why?
Among other things, the advertisement openly portrayed Shell’s gas operations and included qualifying information telling viewers that, according to the relevant 2023 investment figures, 68% of Shell’s investment was in oil and gas, 23% in low-carbon energy solutions and 9% in other non-energy products.
The ASA concluded that viewers were therefore given adequate information about the balance between Shell’s higher- and lower-carbon activities. (ASA)
That subsequent ruling is almost a practical demonstration of what had been wrong with the earlier advertisements.
The first campaign showed the attractive green activities while withholding the scale of the fossil-fuel business.
The later advertisement gave viewers both sides of the equation.
The regulator accepted it.
The wider lesson from the Shell case
The importance of the 2023 Shell decision extends beyond one advertising campaign.
A corporation does not necessarily have to tell an outright lie to produce a misleading environmental impression.
Selective truth can accomplish much the same thing.
Show the wind turbines.
Show the EV chargers.
Show renewable electricity.
Talk about “cleaner energy”.
Talk about “Powering Progress”.
Every statement might be defensible when examined individually.
But if the overwhelming financial and operational context sits somewhere outside the frame, the resulting impression can still be misleading.
That was essentially the principle applied by the ASA.
And Shell’s own subsequent advertising behaviour suggests that the company understood the message.
From “Powering Progress” to “more value with less emissions”
Shell has continued to place the energy transition at the centre of its corporate presentation.
Its current strategy is repeatedly described as delivering “more value with less emissions”, while Shell maintains its ambition to become a net-zero emissions energy business by 2050. (Shell)
There is nothing improper about Shell explaining its lower-carbon investments.
Indeed, shareholders, customers and the wider public need to know what those investments are.
But the 2023 ASA ruling established an equally important principle: the greener portions of Shell’s portfolio should not be presented in a way that causes consumers to misunderstand their significance relative to the company as a whole.
Three years later, Shell’s own annual report supplies exactly the sort of numerical context that was conspicuously absent from those advertisements.
Perhaps the simplest rule for judging future Shell environmental advertising is therefore this:
Do not look only at what Shell puts into the picture. Look for what has been left outside the frame.
Sources
Campaign: ASA bans three Shell ads for greenwashing
Advertising Standards Authority: Shell UK Ltd ruling, 7 June 2023
Advertising Standards Authority: Shell UK Ltd ruling, 9 April 2025
Shell: Annual Report and Accounts 2025
Editorial note: Royal Dutch Shell plc changed its name to Shell plc in January 2022. References to “Shell” in this article encompass the relevant Shell entities and the wider Shell group according to context.
I think this is stronger than treating the Campaign story simply as breaking news, because we can now show both what the ASA objected to in 2023 and what Shell’s own 2025 figures reveal about the continuing importance of proportional context.
The annual report also warrants a separate article later. In particular, the fall in EU Taxonomy-aligned capex from 6.0% to 4.6%, the $2.0 billion allocated to Shell’s own “low-carbon energy solutions” category, and the reasons Shell gives for the decline provide enough material for a focused examination of how the energy-transition rhetoric compares with capital allocation. (Shell)
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