Fewer than three in five influencer advertisements on Instagram and TikTok in the UK are adequately disclosed to consumers, according to a new Advertising Standards Authority (ASA) report.
The UK advertising regulator’s second report on social media ad disclosure compliance found approximately 57% of influencer content on Instagram and TikTok is appropriately labeled as advertising, representing an improvement from previous monitoring but still falling short of expected industry standards.
The ASA study analyzed over 50,000 individual pieces of content across 509 UK-based accounts by 390 influencers during 2024, with content including Instagram Stories, Reels, posts, and TikTok videos.
“Whilst there are signs of improvement of ad disclosure rates on social media by influencer accounts generally, the overall rate of ad disclosure – as determined by this analysis – is still below where we would expect the sector to be,” the ASA states in its report.
Source: ASA
Content Types and Commercial Density
The analysis reveals that approximately one in four pieces of Instagram content captured by ASA monitoring was categorized as advertising, while TikTok showed a slightly lower commercial density, with one in six pieces of content identified as advertising.
Among accounts previously monitored in the ASA’s 2021 report, ad disclosure compliance improved from 35% in 2021 to 49% in 2024. Though the methodological differences between reports mean these figures aren’t directly comparable, the ASA attributes part of this improvement to its compliance monitoring and enforcement actions.
Problem Sectors and Practices
Travel and Fashion emerged as the sectors with the highest rates of inadequate disclosure, with over 50% of ads in both categories either completely undisclosed or improperly labeled.
The report identifies problematic practices, including:
Completely undisclosed content (82% of all non-compliant content across sample groups had no disclosure at all)
Inadequate disclosure labels, including “gifted,” “affiliate,” “pr trip,” and “brand ambassador”
Personalised discount codes presented without proper ad disclosure
Inconsistent disclosure across related content pieces
Undisclosed brand ambassador relationships
For the Fashion and Beauty category specifically, the report highlights instances where content in one format was undisclosed but directed consumers to other pieces of content that contained advertising disclosures, a practice the ASA considers insufficient.
In Travel-related content, the ASA found cases where influencers published multiple undisclosed pieces of content about sponsored trips while only disclosing the commercial relationship in one final post.
Methodology and Sampling
The ASA employed its AI-based “Active Ad Monitoring” system to help capture and categorize content, representing a methodological evolution from the manual processes used in its 2021 report.
The random sample, which the ASA considers most representative of the broader influencer ecosystem, showed marginally better compliance than the other groups. 55% of likely advertising content on Instagram and 60% on TikTok was adequately disclosed.
Interestingly, the study found no statistically significant difference in disclosure rates based on follower count, challenging assumptions that larger, more established influencers might demonstrate better compliance.
Regulatory Enforcement and Recommendations
The ASA maintains that all marketing content must be “obviously identifiable as such” per Section 2 of the Committee of Advertising Practice (CAP) Code, which is currently underpinned by the Consumer Protection from Unfair Trading Regulations 2008 and will be governed by the Digital Markets, Competition and Consumers Act 2024 from April 6, 2025.
The regulator has recently stepped up enforcement actions against high-profile cases of non-disclosure. In May 2024, fashion influencer Grace Beverley received an ASA ruling against six posts promoting her We Are Tala fashion label. Despite the brand’s argument that Beverley was so synonymous with the brand that disclosure was unnecessary, the ASA ruled that the posts failed to make their commercial intent clear.
In a similar case from August 2024, entrepreneur and “Diary of a CEO” podcast host Steven Bartlett faced ASA bans on ads for health brands Huel and ZOE for failing to disclose his financial interests as a board member and investor, respectively. Both companies defended their ads, with ZOE expressing concern about potential broader impacts on the industry if specific disclosures are required.
Key recommendations from the regulator include:
Using clear labeling like “Ad” or “#ad” rather than ambiguous alternatives
Ensuring advertising is disclosed in each relevant piece of content rather than relying on disclosure in bios or in only some related posts
Utilizing platform-provided disclosure tools like “Paid Partnership” or “Commission Paid” labels
For influencers promoting their own brands, ensuring that ownership is “clear by context” or using explicit disclosure labels
The ASA emphasizes that both brands and influencers share responsibility for proper disclosure, noting: “A failure to disclose advertising is not just a breach of the Code, but it is also a likely breach of the law.”
This warning gains significance as legal consequences for disclosure failures emerge globally, exemplified by a recent $50 million class action lawsuit filed against fashion retailer Revolve Group in the United States for allegedly compensating influencers without requiring proper FTC-mandated disclosures.
Industry Response and Next Steps
The ASA reports that guidance on influencer marketing remains among its most-accessed resources, with the organization’s new Self-help Tool for determining ad disclosure requirements being viewed over 10,000 times since its March 2023 launch.
The Influencer Marketing Trade Body (IMTB) joined the Committee of Advertising Practice in March 2023, signaling the sector’s increasing engagement with the self-regulatory system.
More recently, in May 2024, the IMTB joined with counterparts from France and Germany to form the European Influencer Marketing Alliance (EIMA), subsequently becoming an associate industry member of the European Advertising Standards Alliance (EASA). This pan-European coordination reflects what UMICC’s European Affairs Coordinator Quentin Bordage described as “the industry’s economic strength, maturity, and impact on content creators’ followers.”
Looking forward, the ASA plans to share its findings with monitored accounts and the platforms themselves while continuing its enforcement actions. “We will continue to use targeted enforcement action to apply sanctions to influencer accounts who repeatedly, consistently, and recalcitrantly break the ad disclosure rules,” the report states.
In 2024, the ASA received over 3,500 complaints about potential non-disclosure of ads on social media, of which 71% related to Instagram content and 19% to TikTok content.
David Adler is an entrepreneur and freelance blog post writer who enjoys writing about business, entrepreneurship, travel and the influencer marketing space.
Fewer than three in five influencer advertisements on Instagram and TikTok in the UK are adequately disclosed to consumers, according to a new Advertising Standards Authority (ASA) report.
The UK advertising regulator’s second report on social media ad disclosure compliance found approximately 57% of influencer content on Instagram and TikTok is appropriately labeled as advertising, representing an improvement from previous monitoring but still falling short of expected industry standards.
The ASA study analyzed over 50,000 individual pieces of content across 509 UK-based accounts by 390 influencers during 2024, with content including Instagram Stories, Reels, posts, and TikTok videos.
“Whilst there are signs of improvement of ad disclosure rates on social media by influencer accounts generally, the overall rate of ad disclosure – as determined by this analysis – is still below where we would expect the sector to be,” the ASA states in its report.
Source: ASA
Content Types and Commercial Density
The analysis reveals that approximately one in four pieces of Instagram content captured by ASA monitoring was categorized as advertising, while TikTok showed a slightly lower commercial density, with one in six pieces of content identified as advertising.
Among accounts previously monitored in the ASA’s 2021 report, ad disclosure compliance improved from 35% in 2021 to 49% in 2024. Though the methodological differences between reports mean these figures aren’t directly comparable, the ASA attributes part of this improvement to its compliance monitoring and enforcement actions.
Problem Sectors and Practices
Travel and Fashion emerged as the sectors with the highest rates of inadequate disclosure, with over 50% of ads in both categories either completely undisclosed or improperly labeled.
The report identifies problematic practices, including:
For the Fashion and Beauty category specifically, the report highlights instances where content in one format was undisclosed but directed consumers to other pieces of content that contained advertising disclosures, a practice the ASA considers insufficient.
In Travel-related content, the ASA found cases where influencers published multiple undisclosed pieces of content about sponsored trips while only disclosing the commercial relationship in one final post.
Methodology and Sampling
The ASA employed its AI-based “Active Ad Monitoring” system to help capture and categorize content, representing a methodological evolution from the manual processes used in its 2021 report.
The random sample, which the ASA considers most representative of the broader influencer ecosystem, showed marginally better compliance than the other groups. 55% of likely advertising content on Instagram and 60% on TikTok was adequately disclosed.
Interestingly, the study found no statistically significant difference in disclosure rates based on follower count, challenging assumptions that larger, more established influencers might demonstrate better compliance.
Regulatory Enforcement and Recommendations
The ASA maintains that all marketing content must be “obviously identifiable as such” per Section 2 of the Committee of Advertising Practice (CAP) Code, which is currently underpinned by the Consumer Protection from Unfair Trading Regulations 2008 and will be governed by the Digital Markets, Competition and Consumers Act 2024 from April 6, 2025.
The regulator has recently stepped up enforcement actions against high-profile cases of non-disclosure. In May 2024, fashion influencer Grace Beverley received an ASA ruling against six posts promoting her We Are Tala fashion label. Despite the brand’s argument that Beverley was so synonymous with the brand that disclosure was unnecessary, the ASA ruled that the posts failed to make their commercial intent clear.
In a similar case from August 2024, entrepreneur and “Diary of a CEO” podcast host Steven Bartlett faced ASA bans on ads for health brands Huel and ZOE for failing to disclose his financial interests as a board member and investor, respectively. Both companies defended their ads, with ZOE expressing concern about potential broader impacts on the industry if specific disclosures are required.
Key recommendations from the regulator include:
The ASA emphasizes that both brands and influencers share responsibility for proper disclosure, noting: “A failure to disclose advertising is not just a breach of the Code, but it is also a likely breach of the law.”
This warning gains significance as legal consequences for disclosure failures emerge globally, exemplified by a recent $50 million class action lawsuit filed against fashion retailer Revolve Group in the United States for allegedly compensating influencers without requiring proper FTC-mandated disclosures.
Industry Response and Next Steps
The ASA reports that guidance on influencer marketing remains among its most-accessed resources, with the organization’s new Self-help Tool for determining ad disclosure requirements being viewed over 10,000 times since its March 2023 launch.
The Influencer Marketing Trade Body (IMTB) joined the Committee of Advertising Practice in March 2023, signaling the sector’s increasing engagement with the self-regulatory system.
More recently, in May 2024, the IMTB joined with counterparts from France and Germany to form the European Influencer Marketing Alliance (EIMA), subsequently becoming an associate industry member of the European Advertising Standards Alliance (EASA). This pan-European coordination reflects what UMICC’s European Affairs Coordinator Quentin Bordage described as “the industry’s economic strength, maturity, and impact on content creators’ followers.”
Looking forward, the ASA plans to share its findings with monitored accounts and the platforms themselves while continuing its enforcement actions. “We will continue to use targeted enforcement action to apply sanctions to influencer accounts who repeatedly, consistently, and recalcitrantly break the ad disclosure rules,” the report states.
In 2024, the ASA received over 3,500 complaints about potential non-disclosure of ads on social media, of which 71% related to Instagram content and 19% to TikTok content.
The full report is available here.