Influencer Disclosure Generator — ASA + EU compliance
The Collabios influencer disclosure generator outputs the regulator-preferred disclosure wording for every UK + EU jurisdiction in seconds. Pick a country, a platform, and the type of collaboration — get the exact tag (#ad, #publicité, #publicidad, #Werbung, #pubblicità), the placement rules, and the legal basis. Built for worldwide brand teams auditing campaigns across 13 European markets and for UK + EU creators writing compliant disclosures on inbound brand deals.
This country's regulator explicitly rejects English-only hashtags like #ad or #sponsored. The disclosure must be in the local language.
Required disclosure
Publicité
Also acceptable
Partenariat rémunéré
Collaboration commerciale
#publicité
✗ NOT acceptable
#ad
#sponsored
#partenariat
#collab
#spon
Where to place it
Visible dès le début du contenu, avant tout texte développé
Au moins aussi lisible que le reste du texte (taille, contraste)
Sur les vidéos : incrustée à l'image pendant toute la durée pertinente
Pas dissimulée derrière "Lire la suite" ou un repli de caption
⚠ Penalties for non-compliance
€300.000 max fine · Jusqu’à 2 ans d’emprisonnement (jusqu’à 7 ans en cas de circonstances aggravantes). À partir du 1er janvier 2026 (Décret n° 2025-1137 du 28 novembre 2025), un contrat écrit est obligatoire dès que la valeur annuelle totale de la collaboration dépasse 1 000 € HT (rémunération + valeur des avantages en nature). L’absence de contrat écrit ou de clauses obligatoires entraîne la nullité du contrat — la marque perd alors tous ses droits sur le contenu créé. La Loi 2023-451 a été modifiée par l’Ordonnance n° 2024-978 du 6 novembre 2024.
ⓘ This is general guidance based on publicly available regulatory sources, not legal advice. Every campaign should be reviewed by qualified counsel in the target jurisdiction before launch.
How to generate the right disclosure
Four-step workflow to get the regulator-preferred wording for any EU campaign.
Pick the country your audience is in
The disclosure must follow the rules of the audience's country, not the creator's. A French creator posting for a German audience uses German wording.
Pick the platform
Instagram, TikTok, YouTube, and others have slightly different placement rules — first line of the caption, in-video overlay, or pinned comment.
Pick the partnership type
Paid post, gifted product, affiliate code, or organic. The wording changes: "paid partnership" vs. "gifted" vs. "advertising" depending on the country and the consideration.
Copy the wording, placement, and legal basis
You get the exact text the regulator expects, where to put it, and a link to the underlying law (Loi Influenceurs, UWG §5a, RD 444/2024, AGCOM TUSMA, etc.) so legal can verify at the source.
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.
Exemplo ilustrativo
Cenário de exemplo: One campaign, five countries — labelling each post to the local rule
A brand is running a single product launch with creators in the UK, France, Germany, Spain and Italy. The instinct is to write one disclosure line in English and paste it everywhere. That is exactly how a campaign picks up five separate compliance risks: each market enforces a different regulator, a different accepted wording, and a different placement rule.
Instead, the brand runs the generator once per country. It returns the UK ASA / CAP-Code phrasing, the French "Publicité" wording under the Loi Influenceurs, the German Werbekennzeichnung under §5a UWG, the Spanish label under RD 444/2024, and the Italian marker under the AGCom Codice di Condotta — each with the placement note (top of caption, before the "more" fold, not buried in hashtags). The brief now hands every creator the exact line for their audience's jurisdiction instead of a one-size-fits-all guess.
The creator side gets the same certainty. A creator posting to a mixed EU audience checks the country that matches their followers, copies the compliant wording, and places it where the regulator expects it — protecting both the brand's campaign and their own account from an enforcement complaint. Getting the label right is not a formality; it is the cheapest insurance in the whole collaboration.
How do brand teams audit an influencer campaign for ASA + CMA + DGCCRF + AGCom + UWG disclosure compliance?
Five-pass brand-side workflow:
(1) pull every campaign post and screenshot the disclosure tag and its placement (first three lines of caption / platform's 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 generator above (UK: #ad / paid partnership label; France: #publicité / #collaborationcommerciale; Germany: Werbung / Anzeige; Spain: #publicidad / #publi; Italy: #pubblicità in first 3 hashtags); (4) flag posts using only generic English #ad on non-UK audiences as non-compliant; (5) file the audit log with the campaign retention pack — regulator queries land 3-18 months after campaign end, the audit is your defence.
How should a creator write a disclosure to stay ASA + DGCCRF + AGCom + UWG compliant in 2026?
Creator-side workflow:
(1) confirm the audience country of the campaign — your disclosure language follows the audience, not your nationality; (2) place the regulator-preferred disclosure in the first three lines of the caption AND in the platform-native paid-partnership tag (Instagram's "Paid partnership with [brand]" label, TikTok's "Promotional content" toggle, YouTube's "Includes paid promotion" checkbox); (3) the disclosure must be in the audience language — #ad alone is insufficient for any non-UK and non-Dutch audience; (4) for gifted content (no cash but free product), disclose the gifting relationship explicitly — #gifted in the UK is sufficient, #publicité or #partenariatcommercial in France, #regalo or #publicidad in Spain, #pubblicità in Italy; (5) for AI-generated or AI-modified content, additional labelling is required under France's Loi 2023-451 Article 5 and increasingly under UWG enforcement in Germany.
Is #ad enough in Europe?
Only in the UK and Netherlands does the regulator explicitly accept #ad / #advertentie. In France, Germany, Spain, Italy, Belgium, Portugal, Austria, Switzerland, Poland, and Sweden the disclosure must use a local-language term. The generator surfaces the exact wording per jurisdiction.
Does the disclosure need to be in the influencer's language or the audience's language?
The audience's language. A French creator posting for a Spanish brand whose audience is in Spain must use Spanish disclosure ('Publicidad'). The rule follows the consumer-protection logic: protect the people who see the post, not the people making it.
What happens if I use #ad when the audience is in France?
Under Loi Influenceurs (2023-451), it's a non-compliant disclosure. The DGCCRF can fine up to €300,000 and pursue criminal liability. In practice the more common consequence is a regulator letter forcing public correction plus a damaging press cycle.
Does gifted content need disclosure?
In every EU country covered by this tool — yes. Gifting is a "material connection" under the laws. Some countries accept softer wording (Geschenk, regalo, oferta) but a label is mandatory whenever the creator received the product because of their content. #PR or #gifted alone is not sufficient in most jurisdictions.
What are the US disclosure rules — do the FTC Endorsement Guides apply to my campaign?
If your audience is in the United States, the FTC Endorsement Guides (16 CFR Part 255) apply, not the ASA / EU country rules. Under §255.5 any material connection — a paid fee, a free or discounted product, early access, a prize entry, or an affiliate commission — must be disclosed "clearly and conspicuously". Section §255.0(f) defines that standard as "difficult to miss (i.e., easily noticeable) and easily understandable by ordinary consumers", and says the disclosure "should be unavoidable" on social media. The FTC pursues both the brand and the creator, so brand teams running a US campaign should build the disclosure requirement into the brief.
Is #ad enough in the US, and which tags does the FTC say to avoid?
Unambiguous terms — "advertisement", "ad", "sponsored", or a platform paid-partnership label — satisfy the FTC "clear and conspicuous" standard when placed where they are hard to miss (before the caption "more" cut-off, not buried in a block of hashtags). Vague tags that a reader may not decode — "#sp", "#spon", "#collab", "#ambassador", or a bare "thanks [brand]" — do not clearly communicate the connection. For video, the disclosure must be in the video itself (superimposed or spoken), not only in the description; on a live stream, repeat it because viewers join partway through.
Does gifted product or an affiliate link need FTC disclosure even if I was not paid?
Yes. Under 16 CFR §255.5, a material connection exists even when no cash changes hands. Example 7 confirms 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 a commission. A free or discounted product, a free trip, or early access all trigger disclosure. "#gifted" works for the US when placed prominently, but pairing it with the platform paid-partnership tag is the safer baseline.
Is this legal advice?
No. This is operational guidance built from publicly-available regulatory sources, intended to help campaigns avoid the common compliance gaps. Every campaign should be reviewed by qualified counsel in the target jurisdiction before launch.
Fontes primárias
Cada afirmação desta ferramenta está ancorada na regulamentação ou fonte do setor subjacente. Abra qualquer link para ler o original.
