Rules and ethics
Part of UK paid social agencies: rules and ethics, gate by gate
Checking a paid social advert in England before it goes live
Review paid social advertising in England with separate checks for recognition, evidence, consumer law, restricted products and accessibility.
Use this checklist on a paid social advert as people will encounter it, including the preview, image, audio, caption, call to action and destination. It addresses UK rules relevant to an England campaign, but it cannot decide a fact-specific legal or regulated-product question. The rules are enforced by the Advertising Standards Authority (ASA), and the CAP non-broadcast code it applies covers non-broadcast advertising such as print and online, sales promotion and direct marketing.
Before media is booked, the Committee of Advertising Practice (CAP) runs the Copy Advice service: a pre-publication opinion on a specific advert against the CAP Code, the UK Code of Non-broadcast Advertising and Direct & Promotional Marketing. It is a check against the code, not a legal clearance, a platform approval or a guarantee that the ASA will not receive a complaint.
What to take away
- Check the advert as people will encounter it, including preview, image, audio, caption, call to action and destination.
- CAP Code rule 3.7 requires evidence before publication for claims consumers regard as objective and capable of substantiation.
- Screen restricted categories before booking media, and obtain an FCA-perimeter and approval decision for any possible financial promotion.
- Record the approved creative version, targeting, exclusions and authorised publisher, and pause the item if the live placement differs.
- The release sheet needs separate signatures from advertising, consumer, sector, privacy, security, accessibility and commercial reviewers.
Identify the communication
- Name the advertiser and relationship.Record the brand, agency, creator, affiliate, gift, loan, payment, commission or ownership connection.
- Make advertising recognisable.CAP Code section 2 requires marketing communications to be obviously identifiable. Check the first visible or audible presentation, not only expanded text.
- Keep platform controls separate.Meta, TikTok, LinkedIn, X, Snapchat, Pinterest and YouTube each run their own ad policies and review checks. A paid-partnership or content-disclosure feature can support the record, but platform acceptance is not UK clearance.
The CMA's August 2025 brand endorsement guidance tells businesses to brief creators, check published content and act when labelling is wrong. Allocate monitoring and correction to named people.
Advertising recognition checks
- Name advertiser and relationship
- Make advertising obviously identifiable
- Check first visible presentation
- Keep platform controls separate
- Brief creators and monitor content
- Allocate correction to named people
Test every material claim
- Copy the exact objective claim into a register.
- Link documentary evidence that predates publication.
- State population, geography, period and limitations.
- Check that qualifications remain prominent on small screens and short formats.
- Withdraw or amend when the evidence, price, stock or destination changes.
CAP Code rule 3.7 requires evidence before publication for claims consumers are likely to regard as objective and capable of substantiation. Platform acceptance and an agency's previous result are not substitutes for evidence about the advertised product.
Claim evidence register
- Copy exact objective claim
- Link documentary evidence predating publication
- State population, geography, period, limitations
- Keep qualifications prominent on small screens
- Withdraw or amend when evidence changes
Check consumer decisions
Review price components, availability, urgency, comparisons, testimonials, reviews and omissions. The CMA's unfair commercial practices guidance applies the DMCC Act framework to practices from 6 April 2025. Identify the intended consumer and material information needed for the decision; do not assume a caption can repair a misleading creative impression.
Route restricted categories
Screen the product and audience before media is booked. The CAP Code has specialist sections for matters such as health, food, gambling, alcohol, financial products and children, and other regulators sit alongside it: the Gambling Commission for gambling, the MHRA for medicines and medical devices, and the FCA for financial products. A named subject specialist should identify all applicable regulators and approval routes.
For a possible financial promotion, stop and obtain an FCA-perimeter and approval decision. Under the section 21 financial promotion approval route in the Financial Services and Markets Act 2000, an unauthorised person must not communicate an invitation or inducement to engage in investment activity in the course of business unless an authorised person has approved the content or it is exempt. FCA FG24/1 is final guidance explaining that financial-promotion expectations apply across media. Do not treat an influencer, affiliate or short format as outside the question by default.
Verify delivery controls
Record the approved creative hash or version, destination, locations, age rules, exclusions, schedule and person authorised to publish. Confirm account access, billing and the emergency pause route. Changes to copy, offer, targeting or format return to the relevant reviewer.
Test captions, audio alternatives, contrast, resizing, keyboard use and form errors against the agreed accessibility standard. WCAG 2.2 provides technical success criteria, not a universal legal certificate.
Preserve the publication record
Keep the approved advert version, evidence bundle, reviewer names, targeting and exclusion settings, disclosure rendering and publication timestamp together. Capture the live placement after release. If the platform reformats text, removes audio, changes the destination preview or serves a different asset, compare that state with the approval and pause the affected item while reviewers assess it.
The release sheet needs separate signatures from advertising and consumer, sector, privacy, security, accessibility and commercial reviewers. Privacy reviewers work to UK GDPR, the Data Protection Act 2018 and PECR, and accessibility reviewers work to the Equality Act 2010 alongside the agreed technical standard. If one signature is missing, the advert remains on hold. Recheck regulator notices, final versus proposed rules, source dates and the rendered placement immediately before publication.
Before you act
- Name the advertiser and any relationship behind the advert.
- Make the advertising obviously identifiable in its first presentation.
- Copy each objective claim into a register with documentary evidence.
- Review price, availability, urgency, comparisons, testimonials and omissions.
- Screen the product and audience before booking media.
- Record the approved version, destination, targeting and authorised publisher.
Common questions
What evidence is needed before publishing an objective claim?
CAP Code rule 3.7 requires evidence before publication for claims consumers are likely to regard as objective and capable of substantiation. Link documentary evidence that predates publication, and state population, geography, period and limitations. Platform acceptance and an agency's previous result are not substitutes for evidence about the advertised product.
How should a possible financial promotion be handled?
Stop and obtain an FCA-perimeter and approval decision, including the statutory approval route in section 21 of the Financial Services and Markets Act 2000 for an unauthorised person communicating an invitation or inducement to engage in investment activity. FCA FG24/1 is final guidance explaining that financial-promotion expectations apply across media. Do not treat an influencer, affiliate or short format as outside the question by default. The CAP Code also has specialist sections for financial products and other restricted matters.
What should happen if the live advert differs from the approved version?
Capture the live placement after release. If the platform reformats text, removes audio, changes the destination preview or serves a different asset, compare that state with the approval and pause the affected item while reviewers assess it. Changes to copy, offer, targeting or format return to the relevant reviewer.
