Influencer Disclosure Generator — ASA + EU compliance

Why generic #ad isn't enough in the EU

France's Loi Influenceurs (2023, updated 2026), Spain's Real Decreto 444/2024, Germany's UWG §5a, and Italy's TUSMA all reject generic English hashtags like #ad or #sponsored when the audience is local. The disclosure must be in the local language, prominent, and at the start of the post.

Penalties are real: France fines up to €300,000 plus criminal liability (up to 7 years for aggravated breaches); Italy's AGCOM Code of Conduct allows up to €250,000 for general breaches and up to €600,000 for breaches involving child protection; Spain's CNMC actively sanctions both creators and brands under Real Decreto 444/2024; Germany's Wettbewerbszentrale actively pursues non-compliant influencers via civil enforcement (Abmahnungen, Unterlassungsklagen, Vertragsstrafen).

This generator returns the exact wording the regulator expects, the placement rules, and links to the underlying regulation so you can verify everything against the source.

Pick a country to see the rules

How brand teams audit a campaign for ASA + CMA + DGCCRF + AGCom + UWG + CNMC disclosure compliance

Worldwide brand teams running paid creator campaigns into the UK and the EU should run every campaign through a five-pass disclosure audit before payment is released, because the cost of a missed disclosure is now real: under the CMA Digital Markets, Competition and Consumers Act 2024 the UK regulator can refer ASA / CAP Code section 2.1 breaches into CMA enforcement with fines up to 10% of global turnover, France's DGCCRF can pursue fines up to €300,000 plus criminal liability under Loi 2023-451, Spain's CNMC enforces RD 444/2024 sanctions on both creators and brands, Italy's AGCom Codice di Condotta (Delibera 197/25/CONS, effective 5 August 2025) reaches €250,000 for general breaches and €600,000 for minor-protection breaches with joint brand-creator liability, and Germany's Wettbewerbszentrale actively pursues non-compliant influencers under UWG §5a via civil enforcement (Abmahnungen, Unterlassungsklagen, Vertragsstrafen). The five-pass workflow runs: (1) pull every campaign post and screenshot the disclosure tag and its placement (first three lines of caption, platform-native paid-partnership label, on-screen overlay for video); (2) match each post to the audience country — disclosure language follows the audience, not the creator (a UK creator posting for a French audience needs French-language disclosure under Loi 2023-451); (3) check the regulator-preferred wording per country using the Collabios generator above; (4) flag posts using only generic English #ad on non-UK audiences as non-compliant and trigger creator re-issue; (5) file the audit log with the campaign retention pack — regulator queries land 3-18 months after campaign end, and the audit log is your defence. The standard alternative to running this workflow in-house is paying a UK influencer-ad agency between GBP 2,000 and GBP 5,000 per month for what is effectively the same compliance + reporting workflow this free generator covers. Brand teams running the five-pass workflow in-house with the Collabios disclosure generator can close the same compliance loop without retainer cost — and the Collabios marketplace then handles the discovery + payment + dispute legs on a per-collaboration fee rather than the agency-retainer model.

How a UK or EU creator writes a single post that satisfies ASA + DGCCRF + AGCom + UWG simultaneously

UK and EU creators in 2026 increasingly post for audiences in multiple countries on the same content, which means a single post often has to satisfy several regulators at once. The five practical implications are: (1) the disclosure language follows the audience country, not your nationality — a UK creator with a 60% UK / 30% French / 10% Italian audience on a paid post for a UK brand should lead with English (#ad) but add #publicité and #pubblicità in the first three hashtags to satisfy DGCCRF (Loi 2023-451) and AGCom (Codice di Condotta Delibera 197/25/CONS, effective 5 August 2025) for the French and Italian audience shares; (2) the regulator-preferred placement is consistent across regimes — first three lines of caption AND the platform-native paid-partnership label (Instagram's `Paid partnership with [brand]`, TikTok's `Promotional content` toggle, YouTube's `Includes paid promotion` checkbox) — ASA explicitly requires both, and the other EU regulators treat the platform-native label as an aggravating factor when absent; (3) for gifted content (no cash but free product), the gifting relationship must be disclosed explicitly — #gifted is sufficient for UK audiences under ASA / CAP Code section 2.1, but #publicité or #partenariatcommercial is required for French audiences, #regalo or #publicidad for Spanish audiences under CNMC RD 444/2024, and #pubblicità for Italian audiences under AGCom rules; (4) for AI-generated or AI-modified content, additional labelling is required under France's Loi 2023-451 Article 5 (AI-modified image and video disclosure) and increasingly under UWG enforcement creep in Germany — the standard practice is to add #IA / #AI alongside the commercial disclosure, but the regulatory text is still moving and creators with French audiences should monitor DGCCRF guidance updates quarterly; (5) under-16 audience or under-16 creator triggers stricter rules across every regime — AGCom doubles the fine ceiling to €600,000 for minor-protection breaches, French DGCCRF treats minor-targeted disclosure failures as aggravating circumstances, and Germany's BGH I ZR 90/20 (Cathy Hummels precedent) treats minor-protection failures as commercial-purpose deception. The Collabios disclosure generator above outputs the regulator-preferred wording per country and platform combination in seconds, so a creator working across markets does not have to memorise five regimes.

US campaigns: FTC 16 CFR Part 255 (Endorsement Guides) disclosure rules

If your audience is in the United States, the disclosure regime is the FTC Endorsement Guides (16 CFR Part 255), not the ASA / EU country rules above. The underlying logic is the same: the disclosure follows the audience, and any material connection between the brand and the creator must be revealed. Under 16 CFR §255.0(b) an "endorsement" is any advertising or promotional message consumers are likely to believe reflects the opinions or experiences of someone other than the sponsoring advertiser, which covers a sponsored post, a tagged product, or a demonstration. Under §255.5 a material connection (a payment, a free or discounted product, early access, a chance to win a prize, or an affiliate commission) must be disclosed "clearly and conspicuously" whenever the audience would not otherwise expect it. Section §255.0(f) defines "clear and conspicuous" as a disclosure that is "difficult to miss (i.e., easily noticeable) and easily understandable by ordinary consumers," and in interactive media such as social platforms it adds that "the disclosure should be unavoidable."

Brand side: ensuring FTC-compliant disclosure on a US creator campaign

A US brand, or any brand running a campaign into a US audience, carries responsibility for making sure the creators it pays disclose the relationship, because the FTC pursues advertisers as well as endorsers. Practical brand-side rules that flow directly from 16 CFR Part 255: (1) the disclosure must be placed where it is hard to miss. For a caption that means before the "more" cut-off, not buried at the bottom of a block of hashtags or links, since §255.0(f) requires it to be "unavoidable" on social media. (2) It must match the medium of the claim: a visual claim needs a visual disclosure, an audible claim needs an audible one. For video the label belongs in the video itself (superimposed or spoken), not only in the description, and on a live stream it should be repeated because viewers join partway through. (3) Disclosure is required even when no cash changes hands. Example 7 of §255.5 makes clear that a creator who receives an expensive product for free must disclose that fact, and Example 11 extends the same rule to affiliate links that earn commission. (4) Unambiguous terms ("advertisement", "ad", "sponsored", or a platform paid-partnership label) satisfy the standard, whereas a vague "thanks", "ambassador", or an abbreviation a reader may not decode does not clearly communicate the connection. Brands running a mixed US and EU campaign should write both regimes into the brief up front: FTC "clear and conspicuous" language for the US audience share and the local-language regulator wording (from the generator above) for each EU audience share.

Creator side: how to label a US brand deal under the FTC Endorsement Guides

If you are a creator posting for a US audience, the FTC Endorsement Guides put the labelling obligation on you as well as the brand, so a clear disclosure protects you directly. The working checklist: (1) disclose any material connection (a paid fee, a gifted or discounted product, a free trip, early access, or an affiliate commission), because §255.5 treats all of these as connections a viewer "would not reasonably expect". (2) Put the disclosure at the start, not the end: in a caption that means in the first line, above the "more" fold, and never mixed into a cluster of hashtags where it is easy to scroll past. (3) Use plain, unambiguous words. "#ad", "#sponsored", "advertisement", or the platform's "Paid partnership" tag are accepted, while "#sp", "#collab", "#ambassador", or a bare "thank you [brand]" are the kind of vague labels the FTC has said do not clearly communicate the relationship. (4) Match the format: say the disclosure out loud or superimpose it on screen in a video (a description-only note is not enough for a visual claim), and repeat it periodically on a live stream. (5) Remember gifted still counts, so you must disclose a free product even if you were never paid and never promised to post. The platform-native paid-partnership toggle is a good baseline, but on its own it is not always treated as sufficient, so pair it with an in-caption or in-video label. For an EU audience the wording and language change, so use the generator above to get the regulator-preferred term per country.

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