Micro influencer marketing disclosure policy: gifts, labels and checks to write down

If a product arrives without a fee

A free item does not remove the requirement to label resulting promotional content.

A post about a gift received still needs a clear advertising label even when no fee is paid and the creator is not asked to do anything in return. Put this rule in writing before the item is sent.

Put the instruction in the gift note and the policy, including where the creator has not been asked to do anything in return. The free-product question belongs beside that clause, so the recipient can find the same expectation when the item is sent and when the post is checked.

If the deal is paid another way

Set one rule for paid work, discounts and loaned products: any resulting content needs the chosen advertising label. Include it in the policy and every creator brief, rather than relying on a verbal reminder. This gives the campaign manager a repeatable instruction before content goes live.

If promotion spans several panels

Treat each item in a carousel or sequence as its own visibility check. When an item contains promotional messaging, the label needs to appear on that item, not only on the opening panel or another part of the sequence. Record which items were checked, so approval covers the whole format.

Clear label choices include Ad, Advert, AD, advertising and advertisement. Terms to exclude as unclear include #gift, #gifted, #aff, #affiliate, #collab, #PRTrip, #spon and #sponsored. Choose a label that is clear, upfront and prominent, and make sure it is not hidden among hashtags or hard to see against the content background.

If a platform flag is not plain

A paid partnership or branded content tool can support the disclosure, but the policy should not treat the tool as sufficient in every case.

If its display does not make clear that the post is an advertisement, require the creator to add Ad in a visible, upfront position. Keep the standard consistent across the campaign.

If a label is absent at review

Do not leave an unlabelled post unresolved. Contact the creator and any intermediaries promptly, agree how the label will be corrected, and record the outcome.

Repeated failures by a creator put the brand's own campaign at risk, so the policy should state that continued work with that creator may need review.

Set an owner for each handoff

Name the person who approves the content, the person who checks it after publication and the person who arranges a correction.

Set a deadline, such as checking on the working day after posting, and preserve a dated screenshot. Without named owners, a written standard can still fail at the point where somebody needs to act.

Check each post that mentions the brand for an advertising label, following the guidance for brands. Record who completed the check and when. If the label is missing or unclear, the correction owner should follow up promptly rather than assuming another person has already dealt with it.

Keep the clauses usable

Keep the policy to one or two pages and attach it to the campaign paperwork.

Link it to the contract terms so the creator agrees to the standard in writing, then add its clauses to the quality checklist used before payment. Short, verifiable instructions are easier to apply consistently than a verbal briefing.

A working checklist can include the required label and its placement, the rule for gifts, discounts and loaned products, and a label instruction in each gift note. Add the approver, checker and correction owner, the record format with a date and screenshot, and the response to repeated missed labels. Use these items to check whether the policy can be followed, not merely whether it exists.

Keep the proof and reference list

Keep the brief, approved draft, live post and dated check together. When you later audit a micro influencer campaign, these records can show whether the written standard was followed. Review the policy at the end of each campaign and when the rules change, noting what failed and what was changed.

Give the document a reference panel so creators can see which bodies and materials inform the standard. Include the Advertising Standards Authority (ASA), Advertising Codes, CAP and CMA label guide, CMA and Trading Standards Services, and the Digital Markets, Competition and Consumers Act 2024, Schedule 20. Add paid partnership and branded content tools, with a note on when to use them.

Use the rules and compliance guide to place disclosure alongside the other campaign duties. This is general guidance, and a specific dispute or complaint needs a qualified adviser. Keep a short review log with the check results, any correction and the policy change made afterwards.