“Equivalent value” is not equivalent to you: challenging a substitute prize

Two prizes can each carry a £1,000 price tag and offer completely different things.

A family holiday becomes a luxury break for two. A lightweight touchscreen laptop becomes a heavier gaming machine. Cash becomes a voucher that requires you to spend more money before you can use it.

The organiser’s explanation is reassuringly brief: “It’s an upgrade. The replacement is worth more.”

A higher price does not necessarily make something a reasonable replacement for the prize you won. CAP’s guidance looks at both the nature and value of a substitute, not simply whether the organiser can attach an equal or larger figure to it (ASA/CAP, 2026).

However, “I don’t like it” is not a complete argument either. The useful challenge explains what has changed, why that difference matters and how it departs from the original promise.

The rule is “reasonable equivalent”, not “anything with the same price”

Under CAP Code rule 8.15.1, promoters must award the advertised prizes or reasonable equivalents. Consumer legislation also prohibits businesses from claiming to offer a competition or prize promotion without awarding the described prizes or reasonable equivalents (CAP Code, accessed September 2026) (CMA, 2025).

This does not ban every substitution. Products are discontinued, events are cancelled and accommodation becomes unavailable. CAP expressly recognises that, where a concert is cancelled, arranging tickets for another date or discussing an appropriate alternative with the winner can be reasonable (ASA/CAP, 2026).

The question is whether the proposed solution preserves the substance of the prize, rather than merely giving you something.

I would examine three things together:

Value: Is the comparison supported by credible prices, or just optimistic retail figures?

Essential features: Does the replacement retain the characteristics that defined the prize?

Usability: Can it be used under reasonably comparable conditions, without new restrictions or costs changing what you receive?

That is a practical way to organise a complaint, not a statutory three-part test. The following examples show how it works.

A real ruling: a week for eight became four nights for two

In September 2015, the ASA upheld a complaint about a Cornwall Living competition run by Engine House Media.

The winner had chosen a cottage accommodating eight people in four bedrooms and received a reservation confirmation. The organiser subsequently said it was unavailable because of unforeseen circumstances and offered a hotel room instead.

The ASA found that the hotel stay was not equivalent to the cottage holiday and that the competition had not been administered fairly (ASA, 2015).

The useful point is how concrete the differences were. This was not simply “I prefer cottages”. The replacement removed nights, bedrooms and places for guests.

That is the sort of comparison worth making when an organiser tells you that both prizes are, technically, holidays.

Compare real prices, not just recommended retail prices

Suppose an organiser cannot supply the advertised coffee machine and offers another model. The following figures are fictional, used to illustrate the comparison rather than report current product prices.

The organiser calls the replacement a £50 upgrade. Your evidence suggests a substantially different picture.

CAP’s guidance on price advertising warns that comparisons with recommended retail prices can mislead where those figures differ significantly from the prices at which goods are generally sold. A manufacturer’s recommended figure is not sufficient evidence, by itself, that consumers ordinarily pay it (ASA/CAP, 2026).

That guidance concerns advertising price comparisons, not a universal formula for valuing prize claims. Nevertheless, it gives you a good reason to question an unsupported “worth £850” assertion.

For your own comparison, I would save two or three dated examples showing the exact model, condition, specification and included items. Compare new with new, not a new prize with a second-hand auction listing. Include delivery charges, and check that the product is genuinely available rather than an out-of-stock listing displaying an old price.

Use the same approach for both prizes. It is not a fair comparison to use the original item’s highest-ever launch price and the replacement’s lowest clearance price.

Nor is the amount the promoter paid necessarily the answer. If a sponsor supplied a prize free, that does not logically make the promised prize worthless.

Ask how the valuation was reached, not just what number the organiser has chosen.

A more powerful laptop can still be the wrong kind of laptop

Now consider a hypothetical technology prize.

The advert specified a lightweight, convertible laptop with a touchscreen and stylus. The proposed substitute is a more powerful gaming laptop.

Someone who mainly plays games might be delighted. Someone entering for a portable drawing device has lost the features that made this particular prize useful.

The extra storage does not restore touchscreen capability. Better graphics do not make the machine lighter. Calling the replacement “higher specification” picks out some characteristics while overlooking others.

A focused objection would be:

The substitute has more storage, but it is not a convertible and does not support the touchscreen-and-stylus use described in the original promotion. Please explain how it is equivalent in those respects.

This is an illustration of the nature-and-value comparison, not an ASA ruling about these fictional machines.

The same method works with phones, cameras and appliances. Compare storage, compatibility, dimensions, included accessories, condition and any expressly promised warranty. A refurbished item is not identical to a new one merely because both originally had the same launch price.

Be careful with unstated assumptions, though. If the advert only offered “a laptop”, your case is different from one where it named the exact convertible model and highlighted its drawing features.

A holiday’s value includes the people, dates and things you can actually use

Holiday substitutions deserve a comparison of the whole arrangement. Star ratings alone tell you very little about what has disappeared.

Here is another hypothetical example:

A £200 higher valuation does not answer where the children are supposed to sleep.

It also does not explain the loss of included meals and transfers, or the change to the period in which the prize can be used.

CAP’s travel-promotion guidance says significant restrictions on booking or using a holiday prize, including the travel period, must be communicated. These are part of understanding the offer, not incidental details to settle after someone wins (ASA/CAP, 2024).

For a complaint, I would separate missing benefits from additional expenditure.

“Two children are no longer included” identifies a missing part of the prize. A quote showing the additional accommodation cost helps explain its practical impact.

“Transfers were included but now cost £120” identifies a cost shifted to the winner. Keep the quote rather than presenting an estimate as a confirmed bill.

Not every additional expense becomes an automatic compensation entitlement. Nor must a replacement improve aspects of the original prize you happened not to like. The strongest comparison is with what was actually promised and, where relevant, subsequently confirmed.

Dates can be essential without giving you unlimited choice

If the original prize was clearly restricted to one weekend, discovering that you cannot get time off does not, by itself, make those original terms a substitution problem.

It is different if you could use the advertised dates and the organiser then replaces them with dates outside the promised period.

Likewise, an annual pass restricted after winning to weekday mornings is not being assessed solely by its unchanged £200 face value. The newly reduced access is part of the comparison.

The useful question is: what restriction has been added, rather than what flexibility would I now prefer?

Cash, gift credit and discount vouchers are different prizes

Numbers can be especially misleading when a physical prize or cash award becomes a voucher.

Consider these hypothetical offers:

Those are not interchangeable because “£1,000” appears somewhere in the description.

To obtain a £1,000 saving using a 20% discount, you would have to make an eligible £5,000 purchase, assuming there was no cap or other restriction. That calculation does not turn the discount into £1,000 cash.

Check expiry, minimum spend, excluded products, whether credit can be used across several transactions and what happens to any unused balance. These are questions about the proposed substitute, not a reason to assume every voucher is unsuitable.

The Nike ruling: the missing benefit was a limited-edition opportunity

In May 2018, the ASA upheld a complaint about a Nike draw offering the opportunity to buy limited-edition trainers. This was not a draw to receive the shoes free.

The winner paid, but the trainers went missing in transit. Nike refunded the purchase price and offered a 20% discount voucher because it could not supply another pair.

The ASA considered that a reasonable equivalent would have been an opportunity to buy another similarly limited item of clothing at a similar purchase price. The refund and discount did not replace that opportunity (ASA, 2018).

That is an important example of looking beyond a cash total to the feature that made the prize distinctive.

A meet-and-greet, a particular performance or a limited-edition item may have qualities that an unrelated shopping discount does not reproduce. Explain the missing feature without inventing an extravagant monetary value for it.

Usability is more than personal taste — but it needs explaining

There is a difference between:

I prefer the original colour.

and:

The replacement removes the step-free access expressly included in the original prize.

Both may matter to the winner. The second identifies a much more substantial practical difference.

Accessibility should not automatically be dismissed as preference. In the 2017 Go Provence ruling, the ASA upheld a complaint about a holiday competition advertised in a disability lifestyle magazine. It found that the possibility of the accommodation being inaccessible to wheelchair users was a significant condition that should have been made clear (ASA, 2017).

That was a misleading-omission ruling, not a general decision about substitute prizes. It nevertheless demonstrates why a feature determining whether someone can use a prize deserves serious attention.

In a substitution dispute, describe the requirement precisely: step-free access, an accessible bathroom, seated rather than standing tickets, or compatibility with the equipment the advertised prize was designed to work with.

Link it to the original description or agreed arrangements wherever possible. Where disability-related barriers remain, obtain advice on any separate equality-law obligations rather than treating the issue only as a disagreement over value.

Does a substitution clause settle it?

Suppose the conditions say:

The promoter may substitute a prize of equal or greater value.

That tells you to expect the possibility of a replacement. It does not establish that this particular replacement satisfies the promise or the advertising rules.

Ask which original clause the organiser relies on, why substitution is necessary and how it has compared the two prizes.

There is also a difference between exercising a properly disclosed substitution option and adding new conditions after entries have closed. CAP says changes to entry conditions should be exceptional and must not introduce matters that could reasonably have influenced people against participating (ASA/CAP, 2026).

A new requirement to take out a paid subscription, travel outside the advertised period or contribute money is therefore not something to overlook simply because the organiser calls it part of an upgrade.

Can you insist on cash instead?

You can propose cash as a solution. You should not assume that disliking a replacement creates an automatic right to demand the original prize’s advertised value in money.

The CAP Code requires disclosure of whether the promoter may substitute cash where omitting that information would mislead. CAP guidance also recognises that a cash alternative may be appropriate, but says it should match the advertised prize’s value rather than be substantially lower (CAP Code, accessed September 2026) (ASA/CAP, 2026).

That is different from giving every winner a choice between goods and cash.

A sensible resolution could be the original prize sourced elsewhere, a genuinely comparable replacement, missing components added to the offer, or an agreed cash payment.

When the replacement may actually be reasonable

Not every change is a downgrade.

Imagine the original headphones have been discontinued. The organiser offers their current successor: new, with the same principal functions and compatibility, comparable battery life, equivalent cover and a similar ordinary selling price. The only difference you dislike is a less appealing colour.

My assessment would be that this is a much less compelling objection than losing the children’s places on a family holiday. It may be a perfectly sensible substitute.

Context still matters. Colour could be central to a specifically advertised collectible, while a small increase in weight might matter greatly in a prize expressly marketed for lightweight travel.

A complaint should identify a material difference, not treat every difference as material.

Build the comparison before sending the complaint

I would keep the original advert, full terms, winner confirmation and the complete replacement offer together. Save dated model specifications, prices, booking restrictions and relevant correspondence.

Then reduce the dispute to a short comparison:

Promised: a seven-night holiday for four during the stated school-holiday period, including meals and transfers.

Offered: seven nights for two during term time, without meals or transfers.

Requested solution: a replacement retaining the original occupancy, travel period and included services, or another arrangement agreed in writing.

That is more useful than opening with “This is insulting”, however disappointed you feel.

Ask the promoter for a response, even if an agency or supplier communicated the change. Under the CAP Code, responsibility for the promotion rests with the promoter (CAP Code, accessed September 2026).

A message you can adapt

Subject: Proposed substitute prize — [competition and reference]

Thank you for explaining that [original prize] is unavailable.

I am still claiming my prize, but I do not agree that the proposed replacement is a reasonable equivalent.

The original promotion specified [key features]. Your replacement changes [identify the significant differences]. In particular, [explain the practical consequence or additional cost].

I attach a side-by-side comparison and supporting information. Please explain the basis of your valuation and how you have assessed the missing features, restrictions and costs, rather than only the headline price.

My preferred resolution is [the original prize / a comparable replacement retaining the essential features / a proposed agreed alternative].

Please do not treat this enquiry as withdrawal from the competition. Please confirm that my claim remains open while we discuss the substitution, and identify any deadline you consider applicable.

I would appreciate a substantive response by [reasonable date].

Kind regards,

[Name]

Requesting a response within 14 days can be a practical starting point; it is not a universal statutory deadline for resolving a prize dispute.

Before using an unexpected substitute, redeeming a voucher or signing a “full and final settlement”, clarify what you are being asked to accept. Do not assume that describing an item as “goodwill” makes its legal effect obvious. For a substantial disputed prize, take advice before agreeing to close the matter.

What happens if the promoter refuses?

The ASA accepts complaints about unfairly run competitions and prize promotions. Your original description, replacement offer and comparison provide a useful basis for explaining the concern (ASA, accessed September 2026).

However, an upheld advertising complaint is not a court judgment ordering delivery or compensation. The ASA’s sanctions address advertising compliance rather than automatically recovering an individual winner’s loss (ASA, accessed September 2026).

A civil claim requires its own legal basis, evidence and appropriate remedy. A competition prize is not automatically an ordinary retail purchase, so do not assume that a shopping refund template answers the contractual questions. Obtain advice before bringing a substantial or disputed claim, including on costs and the correct defendant (Citizens Advice, accessed September 2026).

GOV.UK lists consumer advice services for England and Wales, Scotland and Northern Ireland (GOV.UK, accessed September 2026).

Ask what has been preserved, not just what has been priced

A good substitute may solve a genuine problem and leave the winner happy. It does not have to be identical in every detail.

But a bigger price tag cannot explain away fewer guests, missing equipment, unusable dates or a new spending requirement.

The strongest challenge is not simply “This is worth less to me.”

It is: “These were the essential features of the prize. These are the features the replacement removes. Please explain how that is a reasonable equivalent.”

UK law, CAP guidance and ASA rulings checked on 7 September 2026. Except for the identified rulings, the comparisons and prices are hypothetical. They illustrate how to assess a substitution, not predetermined legal outcomes; individual rights and remedies depend on the promotion and jurisdiction.