Rules and ethics
Part of UK rules for finance creators in 2027, kept as five separate questions
How to write a finance creator disclosure policy with a separate promotion gate
Write an England finance creator disclosure policy that records commercial interests, sets clear labels and keeps financial-promotion review separate.
A finance creators disclosure policy should tell editors what interests to record, which content needs a visible advertising label, where that label appears and who checks it. It should also say that disclosure does not replace financial-promotion approval, evidence review or a privacy notice.
This method was checked against UK guidance on 5 September 2026. It is not a declaration that any wording is safe in every format. Have advertising and financial-promotion specialists review the policy and its use.
What to take away
- A disclosure policy must state what interests to record, where labels appear and who checks them.
- Disclosure does not replace financial-promotion approval, evidence review or a privacy notice.
- CAP Code Section 2 requires marketing communications to be obviously identifiable with a direct label.
- An ad label does not decide whether words are a financial promotion needing authorised approval.
- Editorial conflicts such as holdings or supplied access may matter to readers even without advertising.
Define the relationships covered
Include direct payment, affiliate commission, free or discounted items, loans, expenses, event access, shareholdings, employment, family interests and promotion of an own product. Record the payer, legal entity, benefit, date and content affected.
The CMA's creator endorsement guidance covers payment, commission, gifts, discounts and own-brand material. Its reach is not limited by follower count. Keep a register even when the editor later decides that a particular item is not an advertisement.
Set a plain advertising rule
CAP Code Section 2 requires marketing communications to be obviously identifiable. The policy should require a direct label at the first point of contact, not a vague phrase, hashtag cloud or profile-only note.
Write examples for article headings, video frames, spoken introductions, captions, stories, email subjects and affiliate links. Do not rely on a channel's paid-partnership tool as the only explanation. The ASA's social-media guidance says the audience should recognise the ad before engaging and notes that a biography disclosure may be inadequate.
Add a separate finance gate
An ad label reveals a commercial relationship. It does not decide whether the words are a financial promotion or whether an authorised person must approve them. Require a qualified reviewer to record the communication, audience, commercial circumstances, product, call to action and legal route.
FCA FG24/1 explains that social-media promotions must meet relevant rules on the channel where they appear. Risks and required information should not be hidden behind optional clicks. Tie any approval to a version and recheck it after substantive edits.
Cover editorial conflicts too
Some interests may not turn an item into advertising but could still matter to readers. Create a separate editorial-conflict note for holdings, professional relationships, recent paid work or supplied access that could affect judgement. State the relevant fact without suggesting independence that does not exist.
Do not call desk research a test or convert partner data into an endorsement. Reviews should say what was and was not examined, who selected the examples, the date, and whether any item or access was supplied.
Build placement and correction controls
The working record should contain the chosen label, placement screenshots, spoken wording, approver, publication URL, date and expiry. Check every fragment that can circulate alone. If a clip is reused, the disclosure must travel with it.
The CMA's updated business and brand guidance describes responsibilities around honest reviews and endorsements. Give readers a correction route and name the person who can amend or remove a post. Log missing or unclear labels as incidents, then review the process rather than silently repairing the page.
Publish the policy with its review date, but keep campaign records private where they contain contractual or personal information. Stop an item when the interest, label, financial-promotion route or evidence remains unresolved.
Before you act
- Record payer, legal entity, benefit, date and content affected.
- Require a direct label at the first point of contact.
- Add a separate finance gate with a qualified reviewer.
- Create an editorial-conflict note for holdings and paid work.
- Log missing or unclear labels as incidents.
- Give readers a correction route and name an owner.
Common questions
What should a finance creators disclosure policy cover?
It should tell editors what interests to record, which content needs a visible advertising label, where that label appears and who checks it. It should also say that disclosure does not replace financial-promotion approval, evidence review or a privacy notice.
Why is an advertising label not enough on its own?
An ad label reveals a commercial relationship but does not decide whether the words are a financial promotion or whether an authorised person must approve them. A qualified reviewer should record the communication, audience, commercial circumstances, product, call to action and legal route.
What should the working record contain for each item?
It should contain the chosen label, placement screenshots, spoken wording, approver, publication URL, date and expiry. Check every fragment that can circulate alone, and if a clip is reused the disclosure must travel with it.
