Advertisment
A sponsored social media advert stated:
“First IVF. How much does IVF really cost in Ireland?
Top IVF Clinic prices. One clear comparison. Download free guide”
Respondents were invited to click on a link within the sponsored advert “Tap to download”. On clicking through, a user was brought to a webpage that stated:
“IVF Cost Comparison Guide: Ireland 2025
Know exactly what you’re paying for – and what you’re not.”
To avail of the comparison guide, a user had to provide their full name and email address.
Cost Comparison Document provided:
A cost comparison document stated: “What’s actually included in IVF and ICSI Pricing?
Before you choose a clinic, take a closer look at what you’re really paying for.
When researching IVF clinics, it’s easy to be drawn to the lowest advertised price, but that’s rarely the full story. Many clinics promote a basic starting fee, but once you add essential treatments like ICSI, embryo freezing, AI Embryo Selection, time-lapse monitoring, or even a follow-up consultation, the final bill can climb significantly. We created this side-by-side IVF/ICSI Cost Comparison to help you spot those hidden extras — and understand the true value behind each clinic’s pricing. While some clinics charge separately for nearly every step, we include all of the most essential services as standard, giving you clarity from the beginning.
This table compares services like:
Whether ICSI and AI embryo selection are included
If time-lapse imaging and embryo freezing are extra
How follow-ups, lab fees, sedation, and basic tests are billed
Payment flexibility and transparent pricing practices
Prices are based on publicly displayed information as of 2025 and may change — we always recommend confirming directly with each clinic. At First IVF, we believe in clear pricing, expert care, and no hidden fees — so you can focus on what matters most: growing your family with confidence and peace of mind.”
The document included a cost comparison chart that detailed a list of prices for services and add on’s compared to the costs of four other unidentified clinics.
Complaint
Complaint: Beacon Care Fertility objected to the advertising on the grounds that they believed that the clinic referred to as ‘Clinic B’ in the comparison chart, related to their clinic and they provided the following reasons why.
They said that as there were only seven IVF clinics in Ireland, including First IVF, even anonymised price comparisons were easily cross-checked by consumers against the limited number of published clinic price lists. They said that several figures in the chart corresponded exactly to their publicly available prices and to no other clinics in that combination, for example:
IVF Package – €5,200
AI Embryo Selection (Caremaps Ai) – €900
Embryo Storage – €800 for 3 years
The combination of these three distinctive price points uniquely identified Beacon CARE Fertility as “Clinic B.”
They said that any consumer researching IVF costs online could confirm these matches within minutes. They said that even without insider knowledge, the pattern of pricing and services made it clear that “Clinic B” referred to Beacon Care Fertility.
They objected to the advertisement on the grounds that the chart had presented misleading price comparisons, incorrectly listing inflated prices for their clinic’s services. They believed that the advertising created the impression that First IVF were more affordable and transparent, while portraying their clinic (shown as “Clinic B”) as more expensive and less trustworthy. They said that patients may make sensitive and costly treatment decisions based on the following incorrect pricing.
They identified the following:
1. The chart listed AI Embryo Selection (€900) and Time-Lapse Monitoring (€900) separately, implying a total of €1,800, when the true cost was €900 (time-lapse was included in their AI).
2. The chart listed an Embryo Freezing Fee (€500) in addition to 3 Years’ Storage (€800), implying a total of €1,300, when the true cost was €800 (freezing was included in their Storage Costs).
They said that they had formally notified First IVF of these inaccuracies on two occasions, and while they were acknowledged, they said they did not amend the chart, meaning it was being knowingly published with incorrect information.
Finally, they said that the chart also marked Clinic B (and all other clinics) with a ‘X’ under “Transparent, All-In-One Pricing,” while awarding First IVF a ‘tick’. They considered that this was misleading as their pricing was clear, itemised, and published online (link provided).
Response
Response The advertisers stated that at no point in the comparison chart were any competitor clinics identified by name, logo, or other proprietary branding. They said that the chart presented anonymised data labelled only as Clinic A, Clinic B, and so on and that the content was designed to provide general market context rather than to target, denigrate, or single out any specific clinic.
They noted that in accordance with ASA Code Section 4.31, comparisons were permitted when they were fair and in the interests of public information. They said that the material in question did not identify any competitor and was based solely on publicly available information and that all pricing information included in the comparison chart was derived from publicly accessible sources, namely the official websites of Irish fertility clinics and associated published pricing lists available at the time of preparation.
The advertisers said that in line with ASA Code Sections 4.9 and 4.10, they had taken reasonable steps to verify accuracy prior to publication by reviewing multiple sources and confirming that the data reflected what was publicly displayed online and that no private or confidential information was used. They said that if notified of subsequent changes or updates to competitor pricing after publication, they would review and amend their materials where appropriate, however, the data used was correct and accurately reflected the information available in the public domain at the time the chart was created.
They said that the intention of the chart was to assist consumers by providing a straightforward comparison of IVF/ICSI costs as advertised online. The accompanying text clearly stated that prices may vary depending on individual circumstances and that patients should consult each clinic directly for the most accurate and up-to-date pricing. They said that the chart did not claim that any clinic was less transparent or trustworthy, rather it had highlighted First IVF’s commitment to clear pricing as part of their patient information approach. They said that this was a factual statement reflecting their own practices and was not a denigration of competitors.
They said that the advertisement was prepared with due regard to relevant Irish and EU legislation governing marketing communications and were confident that it complied with the requirements of the ASA Code and were open to constructive feedback.
Further Information:
The complainant provided a link to their price list – https://www.beaconcarefertility.ie/ivf-costs/
Conclusion
Complaint Upheld.
The Complaints Council considered the detail of the complaint and the advertisers’ response.
The Council noted that the complaint was made on the basis that the clinic identified as ‘Clinic B’ was the complainant’s clinic and that the complainants considered that some of the prices attributed to ‘Clinic B’ were incorrect. The Council noted the intention of the advertisement was to provide a straightforward comparison of IVF/ICSI costs to consumers and that the prices quoted had been obtained from publicly accessible sources. On reviewing the prices detailed in the complaint and listed on the complainant’s website against those listed in the comparison chart, the Council considered that the advertisement had included inaccurate pricing in relation to Clinic B for the services identified.
The Council considered the complaint that the chart entry for “Transparent, All-In-One Pricing” was misleading. They reviewed both parties pricing information at the time of the complaint and considered that both were provided in a similar format, detailing costs, what was included in the headline price, and what was not. They considered that marking Clinic B as X was not accurate.
In the circumstances, the Council considered that the claims in the advertising could mislead consumers and was therefore in breach of Sections 4.1, 4.4, 4.9, 4.10 and 4.32 of the Code.
Action Required
The advertising should not appear in its current form again. The Council reminded advertisers to ensure that comparison charts reflect accurate information that includes a date stamp of when the comparison took place. Where information becomes outdated, it should be amended in a timely manner.
