Rules and ethics
Part of Sponsorship rates: the UK ad rules that shape your fee
A sponsorship disclosure policy that protects your fee
A disclosure policy for sponsorship deals in England: label wording, approval, records and review, and how disclosure work and usage terms belong in the fee.
What to take away
A disclosure policy for sponsorship deals, whatever their sponsorship rates, is a written rule set that says which paid brand deals are labelled as advertising, who checks the label, and where the evidence is kept.
- In England the standards rulebook is the CAP Code, applied by the Advertising Standards Authority, and the work the ASA and CAP do covers online and influencer advertising directly. CAP Code (Edition 12) rules 2.1 and 2.3 sit under the heading Recognition of marketing communications and require marketing communications to be obviously identifiable as such.
- Consumer law sits underneath it. The ASA takes Chapter 1 of Part 4 of the Digital Markets, Competition and Consumers Act 2024 into account when it rules on complaints that an ad is misleading, and the Competition and Markets Authority is the consumer-law enforcer that can act on misleading commercial practices.
- A policy needs a label format, an approval step, a retention period and a named owner, not just a sentence about being transparent.
- Rates quoted in a deal should match the disclosure burden the deal creates, because a heavily produced campaign needs more checking time.
Decide what the policy must cover
Deal types and label rules
- Gifted productlabel required
- Flat fee postslabel required
- Affiliate linkslabel required
- Whitelistinglabel required
- Event appearanceslabel required
- Long-term ambassadorshipslabel required
- Gifted staylabel required
For each type, state whether a label is required and what form it takes. A gifted stay still needs a label. A paid link inside a newsletter does too.
Write the policy for the entity that publishes, not the person who negotiates. That keeps it usable when a freelance creator posts on a brand's behalf.
Our guide to sponsorship rates UK rules sets out the wider rule map, so use it to check that your scope has not missed a deal format.
Set the label and approval rules
A label must be obvious before a viewer engages, not buried after a caption fold. Put it at the start of the caption and in the video itself where the platform allows. The ASA and CAP's Influencers' guide to making clear that ads are ads is the plain-English companion to the rules.
Policy rewrite: before and after
Before
- Label wording
- Thanks to our partner
- Placement
- End of caption
- Approval
- Creator decides alone
- Evidence
- Screenshots in a phone
- Review
- Never
After
- Label wording
- Ad, paid partnership with brand
- Placement
- First line, plus on-screen
- Approval
- Named approver plus backup
- Evidence
- Shared folder, dated
- Review
- Every six months
Ban vague wording. Phrases such as thanks to a partner do not tell a viewer the content is paid. Use ad, advert or paid partnership with the brand named, because an unclear label can breach CAP Code (Edition 12) rule 3.1 on misleading advertising as well as the recognition rules.
Name one approver per deal and give a backup. If the approver is also the creator, the policy is not a control, it is a hope.
Build a second check for regulated categories. Alcohol, gambling, cosmetic interventions and medicines carry extra restrictions, so route those deals to someone with sector knowledge.
Health and safety duties apply to shoots as workplaces under the Health and Safety at Work etc. Act 1974, enforced by the Health and Safety Executive. For productions involving crew, stunts or locations, assign responsibility for checking the relevant risks before filming.
Clause wording you can reuse
- Scopethis policy covers every paid, gifted or discounted brand deal published on our channels.
- Labelpaid content carries ad, advert or paid partnership with the brand named, in the first line of the caption and on screen in the opening seconds.
- Approvalone named approver signs off before publication and records the date and time.
- Ownerthe head of partnerships owns this policy, keeps it current and decides disputed cases.
- Recordsthe deal log, the label used and the approval note are kept for the period the policy owner sets with legal advice, and never less than the life of the contract.
- Reviewthe policy is checked every six months and after any ruling that touches our categories.
Before and after a policy rewrite
Before
- Label wording
- Thanks to our partner
- Placement
- End of caption
- Approval
- Creator decides alone
- Evidence
- Screenshots in a phone
- Review
- Never
After
- Label wording
- Ad, paid partnership with the brand
- Placement
- First line, plus on-screen
- Approval
- Named approver plus backup
- Evidence
- Shared folder, dated
- Review
- Every six months
Who signs off and when
Sign-off should happen before the content goes live, with a short window for urgent posts. Record the approver's name and the time of approval.
If a deal changes after approval, for example a new claim is added, treat it as a new approval rather than an edit.
Price the work the policy creates
Disclosure adds labour: briefing, checking, amending and archiving. Price it into the rate rather than absorbing it.
For example, a team paying GBP 400 a month for editing may need two extra hours a month for compliance checks, so quote that as a line in the deal. Put the figure in the quote as its own line so the brand can see what the disclosure work costs, rather than burying it in the production fee.
The policy also protects the fee in three less obvious ways. Write each into the deal terms:
- Re-approval is billable.If the brand adds a claim after sign-off, the policy treats it as a new approval. Say in the quote that a late change triggers a re-check, and price it.
- Boosting and whitelisting are extra usage.When the brand pays to promote a creator's post or runs it from its own account, the post is still an ad and still needs its label, and the brand gains reach the original fee did not cover. Price that usage, and its duration, separately from the post.
- A failed label costs both sides.An ASA ruling can name both the brand and the creator, and a post taken down early delivers less than was paid for. A clear policy is part of what the brand is buying, which supports holding your rate in negotiation rather than discounting it.
Where a campaign collects audience data, the disclosure policy and the privacy notice must agree with each other. The sponsorship rates data protection in England article explains how to align the two without duplicating paperwork.
Keep a simple log: deal, platform, label used, approver, date, and where the evidence sits. Six columns are enough.
Run a review cycle
Review the policy every six months and after any regulator ruling that touches your category. Check your live posts against the policy, not against memory.
Sample ten posts per quarter. If more than one fails, retrain the team and tighten the approval step.
Keep records for the period the policy sets so you can answer a complaint with evidence rather than recollection. This is general guidance only, and individual cases need a qualified adviser.
Common questions
Does a gifted product need a disclosure label in England?
Yes, where the gift is payment for coverage. The CAP Code treats a benefit received as consideration, so a label is needed even when no money changes hands.
How quickly must a label appear?
It must be clear before a viewer engages with the content. Placing it in the first line of the caption and on screen during the opening seconds meets that test in practice.
Who is responsible if the label is missing?
The brand and the creator can both be held to account. The ASA can act against the advertiser, and the Competition and Markets Authority can act on the consumer-law side against the trader behind the promotion.
Can one policy cover Scotland, Wales and Northern Ireland?
Consumer protection law applies across the UK, so a single policy usually works. Platform rules and sector codes can differ, so check each market before you publish.
