Advertising checks for creator campaigns, from incentive to correction

Creator discovery platforms advertising rules become relevant when discovery feeds a commercial communication. A candidate record or supplier match does not itself show whether later content is advertising, who controls it, whether a claim is supported or whether the audience will recognise it.

What to take away

Identify the arrangement

Before briefing content, record the advertiser, creator, agency, talent intermediary, media payer and platform. Capture every form of consideration, including money, commission, loaned items, gifts, services, access or another benefit. The CMA's updated social-endorsement guidance for brands addresses formal agreements and unsolicited gifts, plus brand monitoring and correction. It is guidance, not case-specific legal clearance.

Confirm creator authority independently. A platform listing does not prove that the creator can accept terms, grant rights, approve claims or instruct a representative. Where a talent intermediary acts, keep the creator's authority record beside the intermediary mandate.

Platform routes and advertising checks

Platform tools add a label. The duty to make the ad obviously identifiable still sits with the brand and the creator under the CAP Code and the CMA rules.

Check recognition in the finished format

Section 2 of the CAP Code says marketing communications must be obviously identifiable; CAP administers the code and the ASA enforces it in the UK self-regulatory system. It is not legislation.

The ASA's advice on recognising influencer advertising, dated 6 August 2026, also says its advice is not legal advice and does not bind the ASA or CAP bodies.

Review the exact post, reel, story, stream, description or other format at normal use. Record wording, placement, timing, prominence, audio or visual presentation, platform control and accessible rendering. A disclosure control is one artefact. The difference is easiest to see in a pair of posts.

A compliant version labels a paid skincare post as an ad in the first caption line, uses the platform's paid partnership label, and matches its claim to a dated study in the claim register. A non-compliant version buries the label after a caption cut, calls a paid placement a gift, and claims clinically proven results with no evidence logged.

Substantiate before approval

Create a claim register with the exact wording, likely audience interpretation, evidence owner, source, date, geography, population, limitations and expiry. Section 3 of the CAP Code covers misleading advertising and substantiation. Supplier dashboards, creator statements and previous posts stay attributed evidence unless independently verified.

Sufficient claim evidence is a dated study or trial that can bear the exact wording, with the sample size, population, method, outcome measures and limitations recorded.

Regulated products need their own qualified lane. A general advertising sign-off cannot approve financial promotions, medicines, gambling, alcohol or another restricted category. Stop if the appropriate specialist has not reviewed the product, audience, claims and media route.

Treat reviews and endorsements carefully

Do not turn a creator's platform score, testimonial or supplier case study into independent proof. Schedule 20 of the Digital Markets, Competition and Consumers Act 2024 addresses fake reviews, concealed incentivised reviews and misleading publication of review information. The relevant unfair-commercial-practices regime applies from 6 April 2025 according to CMA guidance.

Record whether the person had genuine experience, what incentive existed, how that relationship is shown and what was excluded. If evidence is incomplete, remove the review claim rather than soften it.

Protect children without profile guesses

Do not infer a creator's or audience member's age from imagery, language, following or a supplier label. Send possible under-18 involvement to the safeguarding owner. England's child performance and activities guidance covers defined circumstances and cannot determine an individual campaign without facts.

Monitor and correct

Save the approved asset, disclosure, claim evidence, rights record and platform rendering, plus the timestamp. Assign who monitors publication and who may correct or withdraw it.

Set the monitoring rhythm: check each live format at least daily for the first 72 hours and at least weekly for the rest of the campaign. Name a correction deadline, such as amend or withdraw within 24 hours of a breach being found.

Pause when a label disappears, format changes, evidence expires, consideration changes or an unauthorised edit appears. Re-release after the affected advertising, consumer, accessibility, rights and safeguarding reviewers accept new evidence.

Publication remains HOLD pending named specialist review.

Before you act

Common questions

What should be recorded before briefing content?

Record the advertiser, creator, agency, talent intermediary, media payer and platform. Capture every form of consideration, including money, commission, loaned items, gifts, services, access or another benefit. Keep the creator's authority record beside any intermediary mandate.

What does the CAP Code say about recognition?

Section 2 of the CAP Code says marketing communications must be obviously identifiable. The code is administered by CAP and enforced by the ASA in the UK self-regulatory system, and it is not legislation. Review the exact post, reel, story, stream or description at normal use.

When should a campaign be paused?

Pause when a label disappears, the format changes, evidence expires, consideration changes or an unauthorised edit appears. Re-release only after the affected advertising, consumer, accessibility, rights and safeguarding reviewers have accepted new evidence.