UK beauty creator partnerships: CMA ad labels, gifts and beauty filters

Identify paid, gifted and commercial relationships

The CMA's hidden ads principles require creators to label content as advertising when they are paid or otherwise incentivised to endorse a product, service or brand, or have a commercial interest in the brand or its products or services.

Money, commissions, discounts and gifts of products count as payment. The disclosure guidance applies to creators receiving free or discounted products or other incentives in connection with their social media accounts, regardless of follower count. Review the incentive across different business models when deciding what to label.

For a fashion influencer gifting strategy, include a disclosure decision alongside each proposed promotional post. Do not treat a product gift as separate from the payment review. Ask the creator to confirm what they received and whether the planned content promotes the product, brand or service.

Make the ad label visible in each format

The CMA's "Social media endorsements: guidance for content creators" requires incentivised promotional content to be clearly identifiable as an ad and reflect the creator's genuine experience. Labels must be clear, prominent and easy to understand. Check the disclosure in the format audiences will encounter.

Use a disclosure policy to agree the wording and placement before production. Put those decisions in the beauty influencer brief template, alongside the content to be created. Make the label a review item in its own right, rather than relying on a general instruction to be transparent.

Inspect the final image, caption, video opening and each promotional item separately. Where a carousel or sequence allows access to individual posts, each item containing promotional messaging must be labelled. Check the approved version again if its layout or sequence changes before publication.

Keep beauty demonstrations true to experience

Creators demonstrating the benefits of a beauty product should not exaggerate results through a video or photo filter on the platform. Review the demonstration as well as its wording. Keep genuine experience separate from the decision about whether the post needs an ad label.

Ask the creator which results the demonstration is intended to show. Compare the proposed wording with their description of using the product. If an edit makes those results look stronger than the creator's actual experience, request a revised version rather than approving the disclosure alone.

Use risk scenarios to plan what the reviewer should question: a product benefit the creator cannot confirm, an effect altered by a filter, or promotional wording added after approval. Treat these as review prompts, not claims about a particular creator. Resolve the demonstration and disclosure decisions together.

Example: a gifted beauty demonstration

Illustrative example: a beauty creator receives a gifted product and plans a promotional video plus a carousel whose items can be accessed individually. Draft the disclosure before filming. Review the video opening, each promotional carousel item and the product demonstration as separate parts of the same approval.

Example opening: "Ad. This product was gifted. The demonstration reflects my own experience of using it."

The example wording identifies the ad and the gift, but use it only if it describes the arrangement accurately. Place the video disclosure at the beginning of the ad. Label each promotional carousel item, and review any filter for whether it exaggerates the product's demonstrated benefits.

Check connected brands before approval

Creators who own, co-own, work for or are otherwise connected with a brand must disclose that connection and clearly label posts promoting the brand or its products as ads. Include these relationships in the review, rather than checking only whether an outside brand paid for the post.

Use a quality checklist to review the final content against the agreed arrangement, not just the initial brief. Ask the reviewer to mark each decision explicitly. If a label, connection disclosure or beauty demonstration needs revision, return that specific item for correction before approving publication.