The ASA published a report this week into the labelling of influencer advertising. The aim was to investigate what labels and other factors help people understand when influencers are posting advertising content.
So imagine my non-surprise when the conclusion (yes, we're skipping straight to it) was that #AD is the perfect disclosure. Yes, Hashtag Ad. Hashtag Ad is awesome. Hashtag Ad is winning at life. Hashtag Ad will solve Brexit.
Apologies. I got a little delirious. It might be the nearly two years it's taken for the ASA to bring us this anti-startling revelation, maybe its the matchy matchy with my precognitive company name, or maybe it's because the headline puns are just so numerous and delicious ...
ASA endorses Hashtag Ad
ASA embraces Hashtag Ad
CAP and Hashtag Ad are BFFs
Hashtag Ad is marketing perfection and the glorious pinnacle of all that is compliant and goodly.*
Enough. Back to the report.
The ASA's report is actually a significant piece of work and incorporates both public and industry opinion and research. I may have revelled in the conclusion but it's worth a read if you're interested in e.g. finding out what the FTC, over in the US, has been up to when it comes to tackling misleading influencer ads or to understand more about how consumers differentiate between organic and paid ads (if you're in the influencer industry, it's actually quite difficult to put yourself in the mindset of the ASA's average consumer because they're just not as media-savvy as you might expect).
The ASA found that, even when their recommendations for labelling were followed, a "significant percentage" of participants in their research still could not identify influencer advertising posts as definitely an ad.
Product shots, brand names, logos, discounts and calls to action e.g ‘Shop now’ buttons cannot be relied upon as appropriate disclosures. Despite consumers becoming (in my view) increasingly comfortable and knowledgeable about influencer marketing, ads still need to be disclosed with a label such as #AD.
There is a broad international regulatory consensus that online marketing communications and sponsored content must be identifiable to consumers but many countries have produced their own detailed guidelines and published rulings on disclosure. Need country-specific advice? Hashtag Ad can tell you more.
Labels the ASA likes:
Labels the ASA does not like:
In association with
Thanks to [brand] for making this possible
Just mentioning the brand
Placement, visibility and wording of labels are all important factors when indicating that a social media post is advertising. Labels (or other identifiers) needs to be upfront (before people click/engage on the content), prominent, appropriate for the channel and suitable for all the different types of devices on which content might be viewed.
There are simply too many labels in use at the moment and it really is causing confusion. Consumers would benefit from synchronicity and the international standardisation of labels but this is difficult, if not impossible, to achieve in a world with countless regulators, multiple languages and complex, ever-evolving influencer-brand relationships.
Of course, it doesn't help that, here in the UK, we have two bodies telling us how we should be disclosing influencer-brand relationships: ASA/CAP and the CMA.
Although the CMA contributed to the report, the fact remains that the ASA can only comment on, advise on, rule on and punish "ads". The definition of ad does not include influencer posts where the brand has not exerted any editorial control, so all of the above guidance on appropriate labelling and correct disclosure does not apply where there is no editorial control. The CMA has created it's own transparency guidelines and there is some joint guidance that the ASA and CMA created together (pre this report) but this is where things get a little confusing ...
Influencers and brands still have to disclose posts where there is no editorial control but, even though they are not "ads" as defined by the ASA, the CMA recommends labelling them as ... ads! Yes, they're also big fans of Hashtag Ad**. I mean, #AD.
To avoid confusion? Just use Hashtag Ad or #AD. It's for the best.
* The ASA does not endorse Hashtag Ad. But it does endorse #AD. Smoke and mirrors.
** The CMA does not endorse Hashtag Ad. But it does endorse #AD. Swings and roundabouts.