The label was in the draft
The approved caption started with the ad label your policy requires. When the creator posted, they moved the label to the end, after the hashtags, where it is cut off behind "more". On their stories, the label is on the first frame but not the next four. On TikTok, the platform's branded content setting was not switched on. Nobody at the agency checked the live posts, because the draft was approved.
A few weeks later, the client forwards a complaint someone made about the post. They ask whether the agency checks disclosure. The honest answer is "at draft stage".
Why disclosure slips at the last step
Disclosure is agreed in the contract and the brief, checked in the draft, and then depends on what the creator does when posting, which the agency usually does not check.
- Captions are edited when posting, and labels move or disappear.
- Stories and multi-frame content need the label on each frame your policy requires, not only the first.
- Platform paid partnership tools must be switched on at posting, separately from the caption.
- Your policy may differ by market or platform, and creators work to several agencies' rules.
- Nobody records what the live post looked like when it went up.
What a missed label risks
Advertising regulators and consumer protection bodies in many markets expect paid content to be clearly identifiable, and the UK's ASA and CMA have published guidance on this for influencer marketing. Unlabelled posts can lead to complaints, rulings and bad press for the client and the creator, and a question about how carefully the agency managed the campaign. What the rules require is for your advisers and your clients' advisers; what you can control is whether your own policy is checked.
There is also a relationship cost. Creators who are corrected publicly feel let down by an agency that did not catch it, and clients want to know their agency is watching.
Disclosure checks at draft and live
- Your disclosure policy is written into rules per platform and market: the label wording you require, where it must appear, whether the platform tool must be on, and which frames of multi-frame content need it.
- At draft stage, the caption and on-screen text are checked against the rules, and any gap is shown to the reviewer before approval.
- Creators are given the exact label text and placement in their brief, and confirm it.
- When a post goes live, the creator submits the link, and the check reads the live caption and captures a screenshot of the post, including each story frame the creator uploads or shares.
- Live checks compare the caption against the approved version, look for the required label and its position, and record whether the platform's paid partnership label is shown where it can be seen.
- Problems are flagged to the account manager straight away, with the screenshot, so the creator can correct the post quickly.
- Each post's check result, screenshot and time are stored, giving you a record of what was live and when.
| Check | At draft | At live |
|---|---|---|
| Label wording | Caption and on-screen text | Live caption |
| Label position | Start of caption, per policy | Visible before "more" |
| Platform partnership tool | Reminder to creator | Label seen on post |
| Story frames | Each frame in draft | Each frame captured |
The checks apply the policy you set. They do not decide what the law or a code requires, and passing them is not a guarantee of compliance.
Go-live day with a check behind it
The creator posts and submits the link. Within minutes, the check shows the label is present in the caption but after the fold, and the platform's partnership label is missing. The account manager messages the creator, who fixes both. The corrected post is captured again, and both captures are stored. When the client asks about disclosure, you can show the check and the record for every post.
Over a season, you can also see which kinds of mistakes happen most, and tighten the brief for those.
Could a label go missing on your campaigns?
- Disclosure is checked at draft stage only.
- Nobody captures what live posts looked like.
- Story frames after the first are not checked.
- Platform partnership tools are not confirmed.
- Your disclosure policy is not written as rules per platform.