Rules and ethics
Part of UK paid social agencies: rules and ethics, gate by gate
How to build a paid social disclosure policy with a relationship register
Build an England paid social disclosure policy with a relationship register, accessible labels, approval evidence, monitoring and correction routes.
A paid social agencies disclosure policy should reveal the commercial relationship before it can distort how a person understands content. It also needs evidence, rendering checks and a correction route.
What to take away
- Open a relationship record before briefing content, covering payments, gifts, loans, discounts and commissions.
- The audience should not need to open a caption or infer a relationship from a discount code.
- Missing or obscured disclosure means pausing promotion, preserving the visible state and correcting or withdrawing.
Maintain a relationship register
Open a record before briefing content. Name the advertiser, agency, creator, affiliate and platform account. Describe every payment, gift, loan, discount, free service, commission, ownership interest or ongoing ambassadorship. Include start and end dates, affected products, territories, formats and the person who can change the arrangement.
Relationship register fields
- Name advertiser, agency, creator, affiliate, platform account
- Describe every payment, gift, loan, discount, free service
- Include commission, ownership interest, ongoing ambassadorship
- Record start and end dates
- List affected products, territories, formats
- Name the person who can change the arrangement
Worked example row:
| Field | Worked example entry |
|---|---|
| Record ID | REL-001 |
| Advertiser | [advertiser legal name] |
| Agency | [agency name or none] |
| Creator | [creator handle] |
| Affiliate | [affiliate network or none] |
| Platform account | [brand account handle] |
| Benefits | [cash fee], [commission], [loaned product] |
| Dates | [start date] to [end date] |
| Products | [product name] |
| Territories | England |
| Formats | Feed image, story, 30-second video |
| Owner | [campaign manager role] |
The CMA's August 2025 guidance for brands says businesses should ensure endorsements are properly labelled, brief creators, check posts and act when something is wrong.
The underlying duties sit in the Consumer Protection from Unfair Trading Regulations 2008, regulations 3, 5 and 6, which prohibit unfair commercial practices, misleading actions and misleading omissions. The policy should therefore cover informal seeding as well as signed creator campaigns.
Specify wording, placement and timing
Advertising and consumer reviewers approve wording for each format. The audience should not need to open a caption, visit a profile or infer a relationship from a discount code.
Sample label wording:
| Placement | Sample label wording |
|---|---|
| Feed | "Ad by [advertiser]" at the start of the caption and on the image. |
| Story | "Ad by [advertiser]" on the first frame, held for the full frame. |
| Video | "Ad by [advertiser]" in the opening frame and again in the end card. |
ASA advice on recognising social and influencer ads discusses a clear, prominent and upfront "Ad" label and notes that a platform label may not always be enough on its own. CAP Code rules 2.1 and 2.3 require marketing communications to be obviously identifiable and advertorials to be labelled.
Record where the disclosure appears in a feed preview, story frame, short video, livestream, caption, image, audio and destination. Repeat it when a sequence can be entered part-way through. Preserve clarity after cropping, translation and reposting.
Accessibility is a separate acceptance test. Check contrast, text size, display duration, captions, audio description where applicable, keyboard access and screen-reader order. WCAG 2.2 offers technical criteria, but named legal and accessibility reviewers must set the appropriate test for the delivered communication.
Treat platform controls as supplier features
Meta's branded-content help says its paid-partnership label is required for defined exchanges of value. TikTok's current content-disclosure page describes its promotional-content and paid-partnership settings. These global first-party records establish supplier controls and terms.
They do not decide whether the rendered label satisfies UK law or CAP rules in a particular post. In England, the CMA can impose penalties under the Digital Markets, Competition and Consumers Act 2024, and the ASA can publish a ruling or refer a persistent offender to Trading Standards.
Capture the chosen setting, app version, visible result and date. If a supplier changes the label or placement, return the content to review.
Version evidence and approval
Give each item an identifier. Store the relationship record, creator brief, claim evidence, approved script and visual, platform setting, accessibility result, reviewer names and timestamp. Keep the published capture beside the approved version. A platform preview is not evidence of every live placement.
Monitor, correct and withdraw
Name a monitor and frequency for active content. The monitor checks that the relationship, claim, label, destination and format remain as approved. Provide an outside-hours contact and creator response deadline.
If disclosure is missing or obscured, pause promotion and preserve the visible state. Correct only when reviewers confirm the revised presentation; otherwise withdraw it. Record downstream reposts that the parties can control and the attempts made where they cannot. Repeated creator failures trigger the contractual escalation, not an invented penalty.
Before release, obtain separate signatures for advertising recognition, consumer law, claims, privacy, accessibility, platform terms and commercial allocation. Recheck all guidance on publication day. One missing sign-off keeps that item on hold.
Before you act
- Account lead opens a relationship record in the register before briefing content.
- Advertising and consumer reviewers approve disclosure wording for each format.
- Media buyer records where the disclosure appears in each placement in the placement log.
- Platform specialist captures the platform setting, app version, visible result and date in the evidence pack.
- Content owner names a monitor and frequency for active content in the monitoring plan.
- Legal and accessibility reviewers obtain separate sign-offs in the approval sheet before release.
Common questions
What should a relationship register record?
Name the advertiser, agency, creator, affiliate and platform account. Describe every payment, gift, loan and discount. Also record free services and commissions. Add ownership interests and ongoing ambassadorships, plus start and end dates, affected products, territories, formats and who can change the arrangement.
What happens when disclosure is missing or obscured?
Pause promotion and preserve the visible state. Correct only when reviewers confirm the revised presentation; otherwise withdraw it. Record downstream reposts the parties can control and the attempts made where they cannot. Repeated creator failures trigger the contractual escalation, not an invented penalty.
