What does ASA ad-disclosure require for UK affiliate links and brand deals?

Who sets the disclosure rules

The Advertising Standards Authority (ASA) is the UK's advertising regulator. It enforces the CAP Code, which the Committee of Advertising Practice writes. Rule 2.1 requires marketing communications to be obviously identifiable as such, and rule 2.3 requires them to make their commercial intent clear if the context does not. The ASA and the Competition and Markets Authority (CMA) also publish a joint guide, Influencers' guide to making clear that ads are ads.

The placement rules in this article, a label in the first two caption lines and a spoken disclosure in the first 30 seconds, are a cautious working standard built on the ASA's requirement that the label is upfront. They are not rule numbers from the Code. Check the ASA's current guidance when you set your own policy.

Sanctions work in steps. The ASA can publish a ruling that names the advertiser, require the ad to be withdrawn or amended, and add persistent offenders to its list of non-compliant online advertisers. It can refer cases to Trading Standards. Hidden advertising is also an unfair commercial practice under the consumer protection provisions of the Digital Markets, Competition and Consumers Act 2024, which the CMA enforces.

Paid brand deals: what the label must say

A brand deal exists when a brand pays or rewards the creator and has some control over the content, such as approving the script or requiring particular claims. A fee for a post is the clearest case. Label it Ad or Advertisement in the position set out above. Use the word itself. Hashtags such as #sp, #collab or #thanks, and the platform's paid partnership tool on its own, are not enough.

The label should appear on every post in the deal and on every re-share. Where the brand is a financial firm, the label is only the first check, as the final sections explain.

Commission links need an adjacent signal

Commission earned after a sale is a commercial benefit, even when a brand pays no cash directly. Identify the promotion with Ad or Advertisement beside the affiliate URL, or place Ad: affiliate link immediately above it. Comparing the payment arrangements can help establish which kind of relationship applies.

The audience should not have to infer the commercial connection from the destination page or surrounding context. Keep the wording next to the link itself, so the advertising nature is clear before someone engages with the promotion. A label elsewhere on the account does not substitute for disclosure at the link.

Non-cash value still changes the message

A commercial relationship can involve a free product, gifted item, free trial or another benefit rather than a cash fee. The post still needs a clear advertising label. Calling something gifted describes the item received, but that word alone does not tell the audience that the content is advertising.

Separate the label from the description of the benefit: Ad identifies the promotional character, while gifted alone does not. A written disclosure policy can standardise wording for editors and agencies. Keep a record of the chosen wording and location for each post instead of relying on memory.

Static captions require early placement

For a static post, put the label within the first two caption lines, before the platform hides the remainder behind more.

Place it close to the promoted content or link. A bio, link tree or pinned comment may be missed, so it does not replace a disclosure on the post itself.

The practical test is whether a reader can recognise the commercial nature before engaging with the promotion. A label hidden after a block of hashtags, or positioned outside the post, risks being overlooked. Direct wording helps people identify marketing without having to work out the relationship from the surrounding material.

Video needs sound and screen

For a video promotion, speak the disclosure within the first 30 seconds and keep Ad visible on screen while the promotion runs. The message reaches viewers through moving images as well as audio, so a description-only label does not provide both cues where the promotion appears.

A platform's paid partnership tool can add a signal, but it does not replace a plain Ad label in the content. Apply disclosure separately to each format used in a campaign: attaching a label to one version does not automatically cover another. Keep any broader UK rules distinct from this placement check.

Audio requires advance notice

In a podcast or other audio promotion, state the disclosure before the host reads the promotional material. Show notes cannot replace that spoken notice, because a listener may hear the promotion without opening any accompanying text. Make the commercial relationship clear within the audio itself, before the promotional message begins.

Vertical frames need lasting visibility

For Stories and short vertical videos, display the label throughout the time that the promotional frame appears. Some viewers watch without sound, so speech alone may not reach them.

Keep the written disclosure visible for the whole frame rather than relying on a notice that disappears before the promotional content does.

Recognition does not grant financial permission

CAP Code rule 2.1 requires marketing communications to be recognisable as advertising. That recognition check is separate from whether a financial promotion may be made. An Ad label addresses recognition; it does not establish that finance-specific permissions or approval requirements have been met.

The FCA's consumer explanation of financial promotions and its warning about social media influencers are relevant to the separate finance question. Credit, investments, insurance and mortgages usually need an authorised firm, while an unauthorised creator often needs approval under section 21 of the Financial Services and Markets Act 2000. Section 21 allows three routes: the sender is authorised, an authorised person has approved the content, or an exemption in the Financial Promotion Order 2005 (SI 2005/1529) applies. A breach is an offence under section 25. The FCA's guidance on financial promotions on social media (FG24/1) and the Financial Services Register, where you can check an approver's permissions, are the places to start.

Keep that permission check separate from label review. The finance promotion rules and approval handover address the distinct authorisation question. A permitted promotion can still be unclear advertising, while a clear label does not itself provide approval.

Keep a record of each published version

Keep a dated record of the label wording and its position in each caption, video, audio or story format. Recording each version makes it possible to check whether the disclosure appeared in the content itself, rather than being assumed from another post or from the campaign brief.

Before publication, review every format and confirm that its disclosure appears in the required place. Use publication checks to catch a missing label or thin sourcing before the material goes live. Preserve the review with the dated record, so the placement decision can be checked later.

A label used for one format should not be treated as evidence that another version is adequately marked. Retain the wording and placement for each campaign item, alongside its review, so the specific disclosure can be verified. This keeps the record tied to what audiences actually saw or heard, rather than to an assumption about the campaign as a whole.