The UK's influencer guide addresses the deal, not the presenter

The persona

The document under review addresses a category of post, framed around the phrase 'ads are ads.' The UK's Committee of Advertising Practice, working with the Advertising Standards Authority, maintains an influencer's guide now in its third edition, published 23 March 2023, aimed at 'influencers, brands and agencies' as a group rather than at any one presenter type. The guide's own scope statement makes no exception for an account fronted by an operator-run virtual character rather than a person.

What the documents establish

The guide's landing page states its coverage: what the underlying advertising rules are, when a post should carry a disclosure, advice on affiliate marketing, and how to make an ad look like an ad, alongside visual examples and consequences for non-disclosure. CAP's companion resource, the influencer's cheat sheet, narrows this into a practical checklist covering when a social post is likely to count as an ad, treatment of gifted products, affiliate links and discount codes, and guidance for making a disclosure 'clear and prominent.' Both pages describe editions revised in 2018, 2020, and 2023, each incorporating ASA rulings and industry feedback, which signals the guide is treated as a living reference rather than a fixed text.

Character versus company

An influencer's post, human or synthetic, is written to read as personal enthusiasm rather than commercial messaging, which is exactly the appearance CAP's guidance is built to see through. The guide and cheat sheet describe obligations that attach to 'influencers, brands and agencies' collectively: whoever arranges the commercial relationship and posts the content is responsible for making the ad recognizable as such. A virtual persona's in-character recommendation carries no separate standing under this framework; the account behind it is what the guide addresses.

What to watch

Both pages flag that further updates are expected 'due to new legislation,' with the sites noting current guidance 'remains broadly correct with some changes to the legal underpinning,' meaning the third edition may not reflect the guide's next revision. This note could not access the full PDF text of either the guide or the cheat sheet, so specific recommended wording and visual examples are not reproduced here and should be checked directly before being quoted elsewhere.

• Has the anticipated legislative update to CAP's guidance since March 2023 been published?
• Does the cheat sheet's advice on gifted products apply the same way to an operator-run persona's unboxing-style post?
• What specific wording or visual example does the full guide give for adequate disclosure?

CAP's own framing treats the guide as a moving target kept current through rulings and stakeholder input, which is a reason to check the live document's edition date before relying on any summary of it, including this one.