- Short answer
- In the UK, yes: paid posts must be labeled upfront as ads, and your brand is responsible alongside the creator.
- What counts as pay
- Money, commission, discounts or free products, even if you ask for nothing back
- Which label
- 'Ad' or 'Advert', upfront; the ASA advises against 'sponsored'; a tag or code alone isn't enough
- Who enforces
- ASA under the CAP Code; the CMA and Trading Standards under the DMCC Act since April 6, 2025
- Fines
- The CMA says it can fine up to 10% of global turnover for consumer-law breaches
- Shopify Collabs
- Shopify isn't a party to your program terms; no Collabs page we read requires labels
Which posts need an Ad label in the UK?
Any post you pay for. Rule 2.1 of the CAP Code requires marketing to be “obviously identifiable”. The CMA's guidance for brands counts money, commissions, discounts and free products as payment: such a post needs a label even if you ask for nothing back.
The CMA recommends “Ad” or “Advert”, upfront. The ASA advises against “sponsored”; a brand tag, discount code or affiliate link alone is not enough, says the CMA's guide for creators.
Is your brand responsible when a creator skips the label?
Yes. Under the ASA's rules brand and influencer are both responsible, and for affiliate content it goes further:
When the ASA assesses marketing content created by 'affiliates', they typically consider the brand at least jointly responsible – regardless of whether they were aware or had control over the specific content.
The ASA can act, for example, when you control a post or it carries affiliate links. The CMA says DMCC Act rules, enforced by it and Trading Standards, reach further: they apply to brands even without control over the content.
Since April 6, 2025, the CMA can fine a company breaking consumer protection law up to 10% of its global turnover, by its own account.
What should your creator brief and Collabs terms require?
The CMA's guidance for brands asks for:
- a rule in every contract, formal or informal: each post labeled “Ad” upfront, including posts about free gifts;
- the same briefing for agencies you work through;
- your own checks of posts that mention your brand;
- action on unlabeled posts: keeping a creator who repeatedly misses puts you at risk.
Shopify is not a party to your Collabs program agreement, per the Collabs Terms, and no Collabs Help Center page or Terms clause we read in October 2026 requires labels, so the “Ad” rule has to come from your own brief and program terms.
For US audiences, see our answer on FTC affiliate disclosure.
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