Operations
Paid-social agency launch review: creator ad-label checks
A paid-social agency launch review for creator ads: record incentives, inspect labels and sequences, and keep version-specific approvals and corrections.
A paid-social agency's launch review should test the creator asset people will encounter, its advertising label and the decision to release it. Keep the review tied to a specific creative version. Do not treat general campaign approval as evidence that disclosure is clear in the finished presentation.
Make the working standard practical: record why the content is promotional, inspect the disclosure in context, and retain the release decision. Ask the reviewer to assess the finished asset rather than the intention behind it. Keep any unresolved correction attached to the version awaiting approval.
Key takeaways for the launch review
Start by assigning a reviewer, an approver and an owner for any correction. Everyone involved in creating this kind of social-media content must take responsibility for correct labelling. Record each person's role rather than treating review as a task for the creator alone.
Set those responsibilities out in the agency's commercial contracts and disclosure policy. The reviewer checks the finished creative, the approver makes the release decision, and the correction owner follows up when a label needs attention. Keep those roles visible beside the asset record, including any outstanding action.
- Record the creator relationship and any incentive connected with the content.
- Check that the commercial content is labelled and identifiable as an ad.
- Inspect the label's wording, placement and visibility in the finished creative.
- Check each item in a carousel or sequence that contains promotional messaging.
- Record any automatic label and how it appears with the creative.
- Retain the reviewed version, decision, approver and correction owner.
Record the relationship and legal context
Record the incentive associated with each proposed post before reviewing its label. The guidance applies where a creator receives a free or discounted product, direct payment or commission in connection with a social-media account, regardless of follower count. Capture the relationship in the campaign record.
The GOV.UK creator endorsement guidance says all commercial content must be correctly labelled and clearly identifiable as an ad. Promotional content should be labelled as advertising, with the label obvious as soon as anyone engages with it. Check that requirement against the version awaiting the release decision.
The CMA social-media-endorsements investigation was conducted under Part 8 of the Enterprise Act 2002 in respect of potential breaches of the Consumer Protection from Unfair Trading Regulations 2008. The CMA updated its online-reviews and social-media-endorsements guidance on 3 September 2025, adding references to the DMCC Act 2024.
The joint ASA/CMA resource is titled "influencers' guide to making clear that ads are ads". Keep that title with the review record as a reference. Do not treat a reference to guidance or legislation as a finding that a particular creative complies with the applicable requirements.
Inspect the disclosure in the finished creative
Check the disclosure in the final creative, not only in a brief or approval note. Read the label with the image, video or sequence as displayed. Record whether the reviewer can recognise the commercial purpose at the point of engagement, and retain the version examined.
Disclosure labels should not be hidden or buried among hashtags, or made hard to see against the background. Check the actual presentation rather than simply confirming that wording exists somewhere. If the label is unclear in context, record the correction and review the changed creative before making a release decision.
In the Harnbury ruling, the ASA concluded that the post was not obviously identifiable as a marketing communication because its commercial intent was not clear upfront. The case involved Harnbury Holdings Ltd t/a San Carlo and Ms Olender. A clear, prominent "#ad" was the example given for making future ads identifiable.
Under the CAP Code, marketing communications must be obviously identifiable and make their commercial intent clear when context does not. Ms Olender had not included "#ad" or used Instagram's paid partnership tool. Use the agency's advertising rules process to record what the reviewer checked and why.
Check sequences and platform labels
For a carousel or sequence, check every item that contains promotional messaging. Do not use the opening item as a substitute for reviewing the rest. Record which items were examined, then make the release decision against the complete proposed set of creative rather than an isolated preview.
Some platforms have tools to label content automatically, including "paid partnership" and "branded content" labels. If an automatic label is used, inspect how it appears alongside the finished creative and record what the reviewer saw. Do not treat selecting a labelling option as a check of the resulting presentation.
Attach the reviewed creative and decision to the campaign's planning template. If a sequence item or label changes after approval, reopen the review against that version. Use risk scenarios to rehearse what the team will do if an item is missed or a disclosure needs correction.
Example launch-review record
For an illustrative launch-review record, identify the proposed asset and retain the creative alongside the decision. Complete each field against the version awaiting release. Keep the correction owner visible, and check whether the version presented for release matches the version examined by the reviewer.
| Review field | Record for the proposed asset |
|---|---|
| Asset identity | File name or other identifier, and version reviewed |
| Creator relationship | Incentive connected with the content |
| Disclosure | Wording and where it appears in the creative |
| Visibility | Whether the label is clear in the finished presentation |
| Sequence check | Each item containing promotional messaging that was reviewed |
| Platform label | Any automatic label used and how it appeared with the creative |
| Decision | Release, repair or hold, with approver and correction owner |
| Evidence | Reviewed creative and decision record |
Illustrative application: consider a proposed asset with "#ad" buried among hashtags. Record the placement as needing correction rather than approving the asset merely because the identifier is present. Ask for a revised version, inspect its label in the finished presentation, and retain the new decision against that version.
Launch-review questions
Keep the reviewed creative, the label check and the decision together. Record any unresolved point, the person who will resolve it and the version that remains under review. Ask the approver to distinguish a completed review from an asset still awaiting a correction.
What if an approved asset changes?
Reopen the review if a change affects the disclosure's wording, visibility or sequence. Assess the changed asset rather than carrying an earlier decision over automatically. Retain the earlier version separately, identify the replacement, and ask the approver to record a fresh release decision against the revised creative.
Who owns the release hand-off?
Make the hand-off part of the agency's paid-social delivery process. Record which asset was reviewed, who approved it and who must act if a correction is needed. Give the correction owner access to the reviewed version and decision so they can work against the same record.
