UGC marketplaces disclosure policy: a practical workflow

A UGC marketplaces disclosure policy should connect a documented commercial relationship to what an audience can perceive in the finished asset. This workflow is for an English brand commissioning creator-made advertising through a UGC marketplace or service; it does not declare a brand, creator or marketplace compliant. The policy wording and example placement cards below are starting rules. Before release, record the actual asset, placements, appointed owner and campaign response targets.

What to take away

Policy identity

Keep the paid publisher apart from the social platform. Record any independent editorial actor separately and do not contractually describe commissioned material as independent opinion.

Treat the identity table as a completion form: replace every ___ in the working copy before approval. Do not approve a policy or campaign record that lacks a named owner, brand entity, asset and creator.

For campaigns sourced through Insense, Billo, Aspire, Trend, #paid or JoinBrands, record the service used and check its current campaign terms, creator requirements and any disclosure tool or label. Record what the service requires and who is responsible for applying the disclosure; if it offers no relevant control, say so rather than leaving the field blank. Marketplace terms do not replace the brand’s advertising obligations.

Classify every relationship

Enter cash payment, gifted product or service, loan, discount and commission in separate rows. Record affiliate arrangements, paid media and other consideration separately; do not combine them under a vague “benefit” entry. Illustrative row formats—not claims about a real campaign—are Cash | brand → creator | commissioned asset | marketplace or agency, if involved, Gifted product | brand → creator | asset covered | intermediary, if involved and Affiliate commission | programme or brand → creator | tracked content | intermediary, if involved.

Note who offered it, who received it, what content it covers and any intermediary.

For UK advertising, name the applicable rules rather than relying on generic guidance. The CAP Code (non-broadcast) is the self-regulatory rulebook: Section 2 covers recognition of marketing communications and Section 3 covers misleading advertising and evidence for claims. The Advertising Standards Authority (ASA) administers the Code and rules on complaints under it. The statutory consumer-protection framework includes the Consumer Protection from Unfair Trading Regulations 2008 and, from 6 April 2025, the unfair-commercial-practices provisions of the Digital Markets, Competition and Consumers Act 2024. Also consult the CMA’s Social media endorsements: being transparent with your followers guidance. Guidance can help interpret obligations; it is not a substitute for the Code or the law.

Record creator, agency and marketplace statements as attributed claims until verified. Log any AI assistance used for drafting, editing, translation, voice, image or analysis, together with human approval and source rights. Do not assume a universal AI-disclosure duty: check the current platform rules and contract for the actual use, and ask the qualified reviewer whether it changes a claim, commercial indication or consumer impression, or triggers a specific labelling requirement.

Build a channel card

For each intended format, record the disclosure wording, placement, timing, duration, contrast, spoken treatment, caption, transcript, text alternative, truncation state and platform label. Also record the marketplace or service terms checked, the exact disclosure control selected, and a screenshot or recording of the final render, device and test date. As an internal default, disclose the commercial connection prominently with “Ad” or “Advertisement” at the start of the content and caption, and use the platform’s applicable label where available. Check that the disclosure is visible before interaction.

TikTok video: Put “Ad” on the opening frame and at the start of the caption; include a spoken disclosure where the video uses speech. In the post settings, use TikTok’s “Content disclosure and ads” control, switch on “Disclose commercial content” and select “Branded content” for a third-party brand promotion. Check the rendered post and record the selected setting.

Instagram Reels: Put “Ad” on the opening frame and at the start of the caption; include a spoken disclosure where the video uses speech. In the post setup, select Instagram’s “Add paid partnership label” control where applicable. Check the rendered Reel and record whether any brand-partner approval was required and completed.

YouTube Shorts: Put “Ad” on the opening frame and at the start of the caption; include a spoken disclosure where the video uses speech. In the video details, select the paid-promotion declaration: “My video contains paid promotion like a product placement, sponsorship or endorsement”. Check the rendered Short and record the setting.

Build separate cards for Facebook, Snapchat, Pinterest, LinkedIn and blogs or newsletters when those placements are used. Check each channel’s current branded-content or promotion control where available, record the control and its result, and retain a clear “Ad” or “Advertisement” disclosure in the content itself.

A platform setting is not proof that the audience will recognise the advertising. The CAP Code (non-broadcast), particularly Section 2, requires marketing communications to be obviously identifiable; the ASA can rule on complaints and seek compliance with the Code. The reviewer must inspect what the audience sees before interaction, not merely confirm that a setting was selected.

Recognition cannot clear product claims. Link every objective statement to the evidence admitted under CAP Section 3. Store the claim owner, evidence date, scope, qualification, expiry and approved asset version.

Keep other notices separate

Commercial disclosure does not provide permission to use footage, music or a featured person's image. Attach the rights schedule reviewed against the Intellectual Property Office’s (IPO) “Copyright” guidance on copyright and licensing. It also does not replace privacy information. If personal information is collected, assess separately what people must be told under the ICO’s Guide to the UK GDPR, “The right to be informed”.

Accessibility is another independent record. Test the exact published form, including captions and essential visual information, and name the reviewer. Do not treat the disclosure alone as an accessible presentation.

Monitor, correct and withdraw

Set the monitoring source, owner, interval, complaint route, pause authority and evidence archive. Before release, define severity levels and an acknowledgement and resolution target for each; name who escalates a missed target. The brand’s appointed policy owner, identified by name in the policy record, is accountable for corrections; the deputy covers their absence. The response card records the asset and URL, detection time, issue, containment, correction or withdrawal, creator and publisher notifications, retest evidence and closure approval. A missing or obscured disclosure, or a complaint about it, triggers prompt assessment and a pause to controllable distribution while the issue is assessed. Correct or withdraw the asset promptly, and do not restore it until it has been retested and approved. Record actual response times.

The policy remains HOLD. It becomes usable only for the named asset and channels after qualified advertising, consumer, IP, accessibility, privacy and platform reviewers approve the evidence current on that date.

Before you act

Common questions

What should a UGC disclosure policy actually connect?

It should connect a documented commercial relationship to what an audience can perceive in the finished asset. For a brand commissioning through a UGC marketplace or service, record each form of consideration and check disclosure on every final placement. The sample wording and cards are starting rules; record the actual asset, channels, named owner and response targets before lifting the hold.

Why might a platform paid-partnership label not be enough?

The CAP Code (non-broadcast), particularly Section 2, requires marketing communications to be recognisable as such. The ASA administers the Code and rules on complaints; its guidance on recognising influencer advertising explains how the requirement applies in practice. A platform’s paid-partnership label may not always be enough on its own, so the reviewer must inspect what the audience sees before interaction.

What does commercial disclosure not cover?

It does not provide permission to use footage, music or a featured person's image, so a rights schedule is needed. It does not replace privacy information, which needs a separate assessment under ICO guidance. Accessibility is another independent record, tested on the exact published form with a named reviewer.