Public-sector paid social in Wales and Scotland

What to take away

How devolution changes advertising rules in Wales and Scotland

The CAP Code and Advertising Standards Authority apply UK-wide; there is no separate Welsh or Scottish advertising code. Devolution changes public-body language duties and procurement conditions, not the advertising code. Health, education, transport and language policy may still shape a public-sector paid social brief in the devolved nations.

The Advertising Standards Authority enforces the advertising codes across the UK, and its social and political category covers ads that touch public debate. Read it before you promise a client that a devolved campaign is a normal product push.

The UK regulatory layers, from platform policy to ASA ruling risk, stack in a set order. Getting that order wrong is how agencies end up re-cutting assets mid-flight. See Which UK regulatory layers apply to paid social agency work, and in what order.

Where devolution bites is the client side. A Welsh Government body or a Scottish public authority writes its own brief, sets its own language conditions and asks for its own reporting.

Wales and Scotland differ in the conditions a public-sector paid-social agency needs to check. Welsh public bodies may be subject to Welsh Language Standards; in Scotland, procurement rules and the buyer’s Gaelic Language Plan may be relevant. Do not treat either nation as a single set of campaign requirements.

Welsh public-sector paid social and language duties

There is no separate Welsh advertising code or single set of Welsh Government advertising rules that applies to every campaign. The CAP Code still applies. For a Welsh public body, check its Welsh Language Standards compliance notice and campaign brief for the conditions that apply to the work.

Expect a stated purpose, a defined audience in Wales, and a requirement that the campaign is not misleading about who is behind it. Government advertising carries an implied authority that commercial advertising does not.

The practical ask is usually a bilingual campaign from day one. A Welsh-language version is not an afterthought bolted on at the end of production.

Budgets are often split by language and by region. If your media plan cannot show Welsh-language reach separately, you will be asked to rebuild it.

Approvals move slowly. Copy, translations and audience definitions may each need sign-off from different teams, so build slack into the schedule before you book anything. The ASA advice for businesses is a sensible reference when a claim needs checking before sign-off.

A worked example

A Welsh public body wants a paid social campaign on a health topic, with a modest budget and a six-week window.

That sequence is ordinary in Wales. It is not ordinary in a standard UK product campaign. For the English equivalent, see Checking a paid social advert before it goes live.

Where the regimes diverge

Welsh language duties and bilingual paid-social creative

The Welsh Language (Wales) Measure 2011 provides the statutory basis for Welsh Language Standards. The Welsh Language Commissioner oversees compliance, and the standards applicable to a public body are set out in its compliance notice. Check that notice to establish which requirements affect the campaign’s communications and services.

The duty is not simply "add a Welsh translation". The Welsh version should read as if written for Welsh speakers, not converted word for word from English.

Bilingual creative means both languages are live, visible and treated as equal. On paid social that usually means separate ad sets, separate copy and often separate landing pages.

Platform mechanics matter here. Meta Ads Manager and TikTok Ads let you run language variants cleanly, but only if you set them up as distinct assets with their own budgets.

Character limits punish lazy translation. Welsh copy often runs longer than the English, so the primary text and headline need drafting in Welsh first, then adapted.

Targeting by language is not the same as targeting by location. A Welsh speaker in Cardiff and an English speaker in Cardiff are different audiences, and the plan should say which one it is buying.

Creative checklist

Gaelic-language requirements in Scottish public-sector campaigns

The Gaelic Language (Scotland) Act 2005 established Bòrd na Gàidhlig and provides for public authorities to prepare Gaelic Language Plans. That does not create a blanket requirement for every Scottish public-sector advert to be bilingual: check the relevant authority’s plan and the campaign brief for any Gaelic-language commitments that apply.

Where the buyer requires Gaelic creative, agree the language variants, review process, delivery and reporting before production. Treat those requirements as specific to the buyer and campaign, rather than assuming that Scottish public-sector work always requires Gaelic and English assets.

Scottish public-sector procurement and framework requirements

Scottish public-sector procurement is governed by published routes. The Procurement Reform (Scotland) Act 2014 provides a national legislative framework for sustainable public procurement, and the Public Contracts (Scotland) Regulations 2015 also apply to relevant procedures. Scottish Government procurement policy guidance, including the Scottish Procurement Policy Handbook, informs public buyers’ approach. Buyers advertise routes on Public Contracts Scotland, and UK-wide Crown Commercial Service agreements such as Communications Marketplace are also used. Check the buyer’s tender documents to find the route and conditions that apply.

Some campaigns are called off an existing framework rather than tendered from scratch, but the route depends on the buyer and the opportunity. If your agency is not eligible to bid directly, check the tender documents before assuming that subcontracting is an option.

Framework call-offs come with terms you cannot negotiate. Typical clauses cover data handling, such as where campaign data is stored and who may access it, asset accessibility, including captioning and contrast, and named personnel who cannot be swapped without the buyer's agreement. Price those clauses before you price the media.

Accessibility expectations are firm. Captions, contrast and plain language are checked, and a campaign can be paused for a fixable asset problem.

Public bodies also ask for value evidence. Expect questions about cost per outcome, not cost per click, and be ready to explain how you measured it.

Scottish procurement also expects continuity. A supplier who vanishes after the final invoice is unlikely to be called off again. The IAB UK publishes useful background on how UK digital advertising supply chains are organised.

Steps to a compliant Scottish bid

Reporting bilingual campaigns to devolved buyers

Devolved reporting requirements are where most agencies come unstuck. The buyer wants evidence about Wales or Scotland specifically, and platform dashboards rarely give it by default.

Build a reporting template before the campaign starts. Retrofitting language splits and nation-level breakdowns after the fact is slow and often impossible.

Expect three recurring asks: reach in the nation, performance by language, and spend evidence that matches the invoice. Each needs its own line in the report.

Platform metrics are a starting point, not the report. Pull them into a document that answers the buyer's question in the buyer's terms.

The ASA resource library is a useful reference when you need to explain why a claim or a comparison was framed a particular way. Keep the citation in the appendix.

If the campaign touches public debate, note the ASA social and political category in your records. It shows the buyer you considered the category before publishing.

Reporting table to agree upfront

ASA social and political advertising category in devolved contexts

What changes is exposure. A devolved campaign often touches health, education, transport or language policy, which puts it closer to the social and political category than a typical retail campaign.

That matters for claims. A statistic about a Welsh service or a Scottish scheme must be substantiated, and the source should be traceable in your files.

Identity matters too. Ads that look like they come from a government body but do not must not mislead, and disclaimers should be clear on the asset itself.

When in doubt, use the ASA advice for businesses to check how the CAP Code applies to a specific claim before the campaign goes live.

Keep a record of the reasoning. If a complaint arrives, a short note explaining the decision is worth more than a re-creation after the fact. A standing disclosure policy with a relationship register does this well.

Building a bilingual brief that survives both regimes

A brief that works in both Wales and Scotland has to be written once and read by two different sets of conditions. That is achievable if the structure is right.

Start with the buyer. Name the public body, the framework or route, and the language conditions in the first page. Everything else follows from those three facts.

Then separate the creative brief from the compliance brief. Creative answers the audience question; compliance answers the language, procurement and reporting questions.

If you cannot measure it, you cannot promise it, and devolved buyers will ask. The UK paid social rules are worth keeping alongside the brief as a reference.

Build translation and accessibility into the timeline as tasks with owners, not as buffer. Buffer gets eaten; tasks get done.

Finally, document the decisions. A short written record covering who approved what, and when, protects the agency and reassures the buyer.

The one-page brief structure

Common questions