The UGC marketplace entry checklist, from authority and briefs to age uncertainty and exit

Use this UGC marketplaces market entry checklist before admitting real creators or buyer briefs. Entry stays at HOLD until every applicable lane has evidence, an accountable owner and a recovery route. Worked example of a failed lane: a brief claims 'clinically proven' but the advertising lane holds no dated substantiation.

The operator records HOLD, asks for the evidence, and rejects the brief if it does not arrive.

What to take away

Keep creator authority and representative authority as different evidence fields.
Stop onboarding when age is material but unverified; escalate without guessing from appearance or content.
Give every lane an accountable owner, a dated evidence item and a review or expiry date.
Keep a single HOLD record that shows the missing lane and the owner who must clear it.

Define the service and authority

State whether the offer is a self-service marketplace, managed marketplace or content-production service.
Exclude or separately contract any directory, discovery, affiliate, talent, social-network, media-buying or rights-management function.
Name the platform operator, advertiser, agency, creator, representative, featured person and rights holder where applicable.
Verify who may approve the brief, claim, incentive, budget, creator appointment, final asset and publication account.
Use Companies House's company information route for narrow filed facts about incorporated UK parties, then obtain separate trading and authority evidence.
Worked examplean authority log row names the brief approver, the final asset approver and the publication account owner, each with a dated signature.

Control the brief and advertising record

Give every deliverable an owner, version, due event, acceptance rule and rejection path.
Attach the source evidence for objective product claims before creation begins. The CAP Code section 3 includes rules 3.1 on misleading advertising and 3.7 on substantiation and material qualifications.
Record cash, gifts, services, commission and other incentives without assuming that one disclosure label works in every placement.
Test recognition on the final live-sized render. Keep disclosure approval separate from claim approval.
Name who monitors publication and who can correct or withdraw it. The CMA's brand guidance places attention on instructions, monitoring and action when content is wrong.
Worked examplea brief approval log has columns for claim, evidence, owner, status and review date. A row with claim 'clinically proven' and evidence 'dated study attached' can pass; a row with evidence blank stays HOLD.

Record rights asset by asset

Identify the source file, creator, featured people, music, images, graphics, marks and locations.
State the licensed channels, territory, term, paid use, edits, crops, subtitles, reposting and expiry.
Keep creator authority and representative authority as different evidence fields.
Provide a takedown route for disputed or expired material.
Use the IPO's digital-image copyright notice as general UK orientation, then obtain specialist advice for the actual asset.
Sample rights record rowasset [file], creator [name], featured people [names], channels [paid social, organic], territory [UK], term [12 months], expiry [date].

Protect creator and buyer information

Map each personal field to its source, purpose, lawful basis, notice, access, retention and deletion rule.
Do not infer residence, age, protected traits, competence, consent or suitability from a profile.
Separate marketplace onboarding from later promotional contact. The ICO's business-to-business marketing guidance explains that public details can still engage UK GDPR and PECR, including PECR regulation 22 on electronic mail marketing and regulation 6 on cookies.
Propagate corrections and suppression to exports, agencies and buyer systems.
Test the deletion path with fictional records before collecting real information.
Worked examplea data map row links field 'email address' to purpose 'account access', lawful basis 'contract', notice 'privacy notice', retention '24 months after closure' and deletion rule 'automated deletion job'.

Handle age uncertainty and access needs

Stop onboarding when age is material but unverified; escalate without guessing from appearance or content.
Ask a safeguarding specialist whether the actual work needs an England child-performance route. In England, a licence is generally needed for a child under 16, and for a young person aged 16 or 17 who is not in full-time education, unless an exemption applies. GOV.UK explains performance licences for children, but the page does not decide an individual case.
Provide accessible instructions, forms, review media and complaint channels.
Test the completed user journey with accessibility specialists and relevant users rather than accepting a supplier statement as proof.
Worked examplea creator profile states age 15, so the age lane records 'material and unverified', status HOLD, and owner 'safeguarding lead'.

Secure publication and payment

Assign buyer-owned accounts, named users, least privilege, approval logs and emergency revocation.
Follow NCSC social-media account safety guidance on stronger account protection, then test the configured recovery process.
Reconcile creator consideration, marketplace charges, refunds, currency, VAT field and payment status separately.
Define cancellation, rejected-work and complaint routes in the contract without inventing standard terms.
Worked examplea payment reconciliation row keeps separate fields for creator fee, marketplace charge, refund, currency, VAT field and payment status. The fee field is populated from the signed contract, not from the brief.

Prove exit before launch

Export briefs, approvals, contracts, rights, invoices, disclosures, final assets and correction history in usable formats.
Remove access, rotate credentials and verify deletion or retention exceptions.
Keep evidence needed for disputes or statutory records under a reviewed schedule.
Run a fictional failed-brief exercise through withdrawal and closure.
Worked examplean exit export test shows briefs, approvals, contracts, rights, invoices, disclosures and final assets in CSV and PDF, with access removed and credentials rotated.

Do not enter the market with a live commission until named advertising, consumer, privacy, PECR, IP, safeguarding, accessibility, security, tax and contract reviewers have signed their separate gates. Record a HOLD decision wherever evidence remains missing.

Costs, timelines and roles

Market entry needs named role owners, not a single checklist owner. Typical roles are an operations lead, rights manager, data protection lead, safeguarding lead, security lead, finance lead and contract reviewer. Costs are driven by legal review, rights clearance, data protection advice, accessibility testing, security setup, payment reconciliation and exit testing.

Timelines depend on evidence lead times, legal review and testing. Typical ranges are weeks for a self-service entry and longer for a managed service with paid creators. Resource the rights and data lanes first because they usually need the longest evidence trail.

Pre-launch sign-off list

Service definitionowner [operations lead], evidence [signed scope note].
Brief and claim recordowner [marketing lead], evidence [approval log with dated substantiation].
Rights scheduleowner [rights manager], evidence [asset-by-asset record with expiry dates].
Data mapowner [data protection lead], evidence [record of processing activities].
Age and access gateowner [safeguarding lead], evidence [escalation note and licence determination].
Account and payment controlsowner [security lead and finance lead], evidence [access review and reconciliation].
Exit testowner [operations lead], evidence [export test report and deletion confirmation].

Common questions

What must be in place before admitting real creators or buyer briefs?

Every applicable lane must have evidence, an accountable owner and a recovery route. A missing or expired item keeps entry at HOLD. The operator assigns an owner and a recovery route before admitting real creators or buyer briefs.

How should age uncertainty be handled during onboarding?

Age is a gate, not a profile inference. If age is material and unverified, stop onboarding, record HOLD, and ask a safeguarding specialist to decide whether the England child performance route applies. The specialist decision is the evidence needed to clear the lane.

What evidence must be kept for rights and exit?

Use the asset-by-asset rights row and the exit export test. Keep the source file, creator, featured people, music, images, graphics, marks, locations, licensed channels, territory, term, paid use, edits, crops, subtitles, reposting and expiry. For exit, export briefs, approvals, contracts, rights, invoices, disclosures, final assets and correction history in usable formats.