What you must disclose about advertising in your country

An affiliate link and a sponsored post are advertising, and they must be labelled. The requirements differ more than people expect: in some places a word at the top of the post is enough, in others you need a state-issued identifier, and in others an advertising licence.

This is not legal advice. Below is what the regulators' documents say, регуляторов, со ссылкой на документ. What follows from this лично depends on where you live, on the platform and on your contract; that question is for a lawyer, not a handbook.

USA

When it is mandatory. 16 CFR 255.5(a): «When there exists a connection between the endorser and the seller of the advertised product that might materially affect the weight or credibility of the endorsement, and that connection is not reasonably expected by the audience, such connection must be disclosed clearly and conspicuously. Material connections can include a business, family, or personal relationship. They can include monetary payment or the provision of free or discounted products (including products unrelated to the endorsed product) to an endorser, regardless of whether the advertiser requires an endorsement in return»; «A material connection needs to be disclosed when a significant minority of the audience for an endorsement does not understand or expect the connection» the text of section 255.5 was obtained through the open eCFR API (versioner v1, title 16 issue date 2026-07-31); ftc.gov and the ecfr.gov web page return 403 to an ordinary request. No translation is made; the quotation is verbatim. Rule 255.5(b) Example 2: if the payment is "ordinarily expected by viewers" (a celebrity in a TV commercial), no disclosure is required source, checked 2026-08-04

In what words. There are no verbatim mandatory wordings in 16 CFR 255; 255.5(a): "A disclosure of a material connection does not require the complete details of the connection, but it must clearly communicate the nature of the connection sufficiently for consumers to evaluate its significance". FTC staff recommendations (Disclosures 101): "Simple explanations like “Thanks to Acme brand for the free product” are often enough if placed in a way that is hard to miss"; "So are terms like “advertisement,” “ad,” and “sponsored”"; "On a space-limited platform like Twitter, the terms “AcmePartner” or “Acme Ambassador” (where Acme is the brand name) are also options"; "It’s fine (but not necessary) to include a hashtag with the disclosure, such as #ad or #sponsored"; "Don’t use vague or confusing terms like “sp,” “spon,” or “collab,” or stand-alone terms like “thanks” or “ambassador”"; "The disclosure should be in the same language as the endorsement itself" the FTC staff brochure "Disclosures 101 for Social Media Influencers", the date "November 2019" at the bottom of the page; the FTC itself notes in 255.0(a), footnote 1, that staff guidance is "not approved by or binding upon the Commission". The words are given verbatim in English source, checked 2026-08-04

Where it goes. 16 CFR 255.0(f): "“clear and conspicuous” means that a disclosure is difficult to miss (i.e., easily noticeable) and easily understandable by ordinary consumers… If a communication’s representation necessitating a disclosure is made through visual means, the disclosure should be made in at least the communication’s visual portion; if the representation is made through audible means, the disclosure should be made in at least the communication’s audible portion; and if the representation is made through both visual and audible means, the disclosure should be made in the communication’s visual and audible portions… In any communication using an interactive electronic medium, such as social media or the internet, the disclosure should be unavoidable". Disclosures 101: "The disclosure should be placed with the endorsement message itself"; "Disclosures are likely to be missed if they appear only on an ABOUT ME or profile page, at the end of posts or videos, or anywhere that requires a person to click MORE"; "Don’t mix your disclosure into a group of hashtags or links"; for video — "the disclosure should be in the video and not just in the description uploaded with the video"; for a live broadcast — "the disclosure should be repeated periodically" the definition of "clear and conspicuous" is section 255.0(f) of the Guides; the clarifications on placement are the FTC staff brochure at ftc.gov/business-guidance/resources/disclosures-101-social-media-influencers. In the mandatory rule 16 CFR 465.1(c)(4) the same idea is put more harshly: "A disclosure is not clear and conspicuous if a consumer must take any action, such as clicking on a hyperlink or hovering over an icon, to see it" source, checked 2026-08-04

Who is liable. Both the advertiser and the creator. 16 CFR 255.1(d): "Advertisers are subject to liability for misleading or unsubstantiated statements made through endorsements or for failing to disclose unexpected material connections between themselves and their endorsers… An advertiser may be liable for a deceptive endorsement even when the endorser is not liable". 255.1(e): "Endorsers may also be liable for failing to disclose unexpected material connections between themselves and an advertiser, such as when an endorser creates and disseminates endorsements without such disclosures". Disclosures 101: "As an influencer, it’s your responsibility to make these disclosures… Don’t rely on others to do it for you". On review platforms, 255.4(b)(3): "If, however, the review website does not take payments for higher rankings, but receives payments from some of the headphone manufacturers, such as for affiliate link referrals, it should clearly and conspicuously disclose that it receives such payments" quotations from sections 255.1(d), 255.1(e), example 3 to 255.4 and the Disclosures 101 brochure source, checked 2026-08-04

Penalties. The Guides themselves do not establish sanctions. 16 CFR 255.0(a): "The Guides provide the basis for voluntary compliance with the law by advertisers and endorsers. Practices inconsistent with these Guides may result in corrective action by the Commission under section 5 if, after investigation, the Commission has reason to believe that the practices fall within the scope of conduct declared unlawful by the statute". The monetary ceilings under the FTC Act are announced in 16 CFR 1.98: "Section 5(l) of the FTC Act, 15 U.S.C. 45(l)—$53,088", "Section 5(m)(1)(A) of the FTC Act, 15 U.S.C. 45(m)(1)(A)—$53,088", "Section 5(m)(1)(B)… —$53,088"; the introductory clause: "The following maximum civil penalty amounts apply only to penalties assessed after January 17, 2025" the sums are taken verbatim from 16 CFR 1.98 (the indexation of fines); we do not interpret the tie between a particular breach and a particular provision. Separately in force is the mandatory rule 16 CFR Part 465 "Rule on the Use of Consumer Reviews and Testimonials" (89 FR 68077, 22.08.2024), adopted under 15 U.S.C. 57a source, checked 2026-08-04

Who it applies to. Disclosures 101: «If posting from abroad, U.S. law applies if it’s reasonably foreseeable that the post will affect U.S. consumers. Foreign laws might also apply». On language: «The disclosure should be in the same language as the endorsement itself». 16 CFR 255.0(f): «When an endorsement targets a specific audience, such as older adults, “ordinary consumers” includes members of that group» the connecting criterion is neither citizenship nor residence but the foreseeable effect on US consumers; the wording is from the FTC staff brochure source, checked 2026-08-04

The document in force. 16 CFR Part 255 "Guides Concerning Use of Endorsements and Testimonials in Advertising", Source: 88 FR 48102, July 26, 2023; the accompanying mandatory rule 16 CFR Part 465 "Rule on the Use of Consumer Reviews and Testimonials", Source: 89 FR 68077, Aug. 22, 2024; the FTC staff brochure "Disclosures 101 for Social Media Influencers", November 2019 the dates of the sources are the Source: lines in the text of Parts 255 and 465 issued by the eCFR API for the title 16 issue date of 2026-07-31 source, checked 2026-08-04

European Union

When it is mandatory. Directive 2005/29/EC, Article 7(2): "It shall also be regarded as a misleading omission when… a trader hides or provides in an unclear, unintelligible, ambiguous or untimely manner such material information as referred to in that paragraph or fails to identify the commercial intent of the commercial practice if not already apparent from the context, and where, in either case, this causes or is likely to cause the average consumer to take a transactional decision that he would not have taken otherwise". Annex I point 11 (prohibited in all circumstances): "Using editorial content in the media to promote a product where a trader has paid for the promotion without making that clear in the content or by images or sounds clearly identifiable by the consumer (advertorial)". Annex I point 11a: "Providing search results in response to a consumer’s online search query without clearly disclosing any paid advertisement or payment specifically for achieving higher ranking of products within the search results". Guidance 2021/C 526/01, § 4.2.6: "The commercial element is considered to be present whenever the influencer receives any form of consideration for the endorsement, including in case of payment, discounts, partnership arrangements, percentage from affiliate links, free products (including unsolicited gifts), trips or event invitations etc. The presence of a contract and monetary payment is not necessary to trigger the application of these rules" the texts were obtained through the open EU publications portal publications.europa.eu/resource/celex/... (Accept: application/xhtml+xml); the eur-lex.europa.eu page itself returns an empty 202 response to an ordinary request source, checked 2026-08-04

In what words. There are no verbatim mandatory words either in the directive or in the guidance. The directive requires the commercial intent to be indicated: Annex I point 11 — "without making that clear in the content or by images or sounds clearly identifiable by the consumer". Guidance 2021/C 526/01, § 4.2.6: "According to Article 7(2) all commercial communications must be clearly indicated as such, unless already apparent from the context"; "The disclosure of the commercial element must be clear and appropriate, taking into account the medium in which the marketing takes place, including the context, placement, timing, duration, language, target audience and other aspects" the EU does not prescribe specific words or hashtags; the guidance refers directly to the national self-regulatory bodies — footnote 361 (in the text, a note to the section): "further self-regulatory guidance regarding specific considerations and examples of disclosures for influencer marketing have been provided by national advertising self-regulatory bodies". the texts were obtained through the open EU publications portal publications.europa.eu/resource/celex/... (Accept: application/xhtml+xml); the eur-lex.europa.eu page itself returns an empty 202 response to an ordinary request source, checked 2026-08-04

Where it goes. Guidance 2021/C 526/01, § 4.2.6: «The disclosure must be sufficiently salient to adequately inform the average or vulnerable consumer that receives the content. For example, the disclosure cannot be considered adequate in case the information concerning the commercial communication is not displayed prominently (e.g. hashtags at the end of a lengthy disclaimer; merely tagging a trader) or requires the consumer to take additional steps (e.g. click on “read more”)»; «It is also necessary to individually label each commercial communication as it reaches consumers, even if the influencer is engaged in a broader endorsement arrangement with a trader/brand» the texts were obtained through the open EU publications portal publications.europa.eu/resource/celex/... (Accept: application/xhtml+xml); the eur-lex.europa.eu page itself returns an empty 202 response to an ordinary request source, checked 2026-08-04

Who is liable. The creator, the advertiser and the platform alike. Guidance 2021/C 526/01, § 4.2.6: "For the purposes of the UCPD, an influencer would qualify as a “trader” or, alternatively, as person “acting in the name of or on behalf of a trader”. Persons that frequently carry out promotional activities towards consumers on their social media accounts are likely to qualify as “traders”, regardless of the size of their following"; "Depending on the circumstances of the case, the breach could be attributed both to the influencer or to the trader/brand that has engaged the influencer and benefits from the endorsement. The presence of editorial control by the trader is not necessary to trigger the application of these rules but could serve as a factor in the determination of its liability"; "In addition to the obligations of influencers and brands, the online platform that is used for the promotional activities is subject to its own obligations of professional diligence under the UCPD… e.g. to provide specific and appropriate disclosure tools in the platform’s interface" the texts were obtained through the open EU publications portal publications.europa.eu/resource/celex/... (Accept: application/xhtml+xml); the eur-lex.europa.eu page itself returns an empty 202 response to an ordinary request source, checked 2026-08-04

Penalties. Directive 2005/29/EC, Article 13(1): "Member States shall lay down the rules on penalties applicable to infringements of national provisions adopted pursuant to this Directive… The penalties provided for shall be effective, proportionate and dissuasive". Article 13(3): "…the maximum amount of such fines being at least 4 % of the trader’s annual turnover in the Member State or Member States concerned". Article 13(4): "For cases where a fine is to be imposed in accordance with paragraph 3, but information on the trader’s annual turnover is not available, Member States shall introduce the possibility to impose fines, the maximum amount of which shall be at least EUR 2 million" these are the minimum ceilings that the Member States are obliged to introduce; the specific amounts are set by national law. The clause of Article 13(3) applies to coordinated actions under Regulation (EU) 2017/2394. the texts were obtained through the open EU publications portal publications.europa.eu/resource/celex/... (Accept: application/xhtml+xml); the eur-lex.europa.eu page itself returns an empty 202 response to an ordinary request source, checked 2026-08-04

Who it applies to. Directive 2005/29/EC, Article 3(1): "This Directive shall apply to unfair business-to-consumer commercial practices, as laid down in Article 5, before, during and after a commercial transaction in relation to a product". The connection is to the status of "trader" and to the consumer, not to the creator's citizenship; guidance 2021/C 526/01 § 4.2.6: "The obligations to be clear about the commercial communication apply to traders regardless of whether they are the suppliers of the products". The directive is an act of indirect effect: the national laws of the Member States adopted in implementation of the directive apply no direct provision on territorial or language scope was encountered in the text of the directive; the last sentence is not an interpretation but a direct consequence of the nature of a directive, which is spoken of in Article 13(1) ("infringements of national provisions adopted pursuant to this Directive"). the texts were obtained through the open EU publications portal publications.europa.eu/resource/celex/... (Accept: application/xhtml+xml); the eur-lex.europa.eu page itself returns an empty 202 response to an ordinary request source, checked 2026-08-04

The document in force. Directive 2005/29/EC of the European Parliament and of the Council of 11 May 2005 "concerning unfair business-to-consumer commercial practices in the internal market" ("Unfair Commercial Practices Directive"), OJ L 149 11.6.2005, p. 22; we read the consolidated version 02005L0029 — EN — 28.05.2022 — 001.001. The interpretation: COMMISSION NOTICE — "Guidance on the interpretation and application of Directive 2005/29/EC…", (2021/C 526/01), Official Journal C 526/1 of 29.12.2021, section 4.2.6 "Influencer marketing" the consolidated text is marked "This text is meant purely as a documentation tool and has no legal effect"; the authentic versions are in the Official Journal. the texts were obtained through the open EU publications portal publications.europa.eu/resource/celex/... (Accept: application/xhtml+xml); the eur-lex.europa.eu page itself returns an empty 202 response to an ordinary request source, checked 2026-08-04

United Kingdom

When it is mandatory. CAP Code, rule 2.1: «Marketing communications must be obviously identifiable as such»; 2.3: «Marketing communications must not falsely claim or imply that the marketer is acting as a consumer or for purposes outside its trade, business, craft or profession; marketing communications must make clear their commercial intent, if that is not apparent from the context»; 2.4: «Marketers and publishers must make clear that advertorials are marketing communications; for example, by heading them “advertisement feature”». ASA online advice: «Section 2 of the CAP Code requires that marketing communications are obviously identifiable as such»; «Whenever a brand gives an influencer a payment or any other incentive (requested or unsolicited), or an influencer is otherwise personally or commercially connected to the brand (e.g., owner, employee, shareholder, director or have any other commercial or personal interest), any content featuring or referring to the brand will need to be obviously identifiable as advertising» the texts of rules 2.1–2.4 were read in section 2 of the CAP Code, "Recognition of marketing communications", at asa.org.uk/type/non_broadcast/code_section/02.html. The quotations are verbatim in English; no translation is made. ASA's robots.txt closes the paths */type/capcode/code_rule/*, so the individual rule pages were not requested source, checked 2026-08-04

In what words. The ASA lists the labels directly. Sufficient: "Ad", "Advert", "Advertising", "Ad Feature", "Advertisement Feature" — "all very likely to be considered acceptable by the ASA (with or without a “#”)". Insufficient: "Supported by", "Funded by", "Gifted", "In association with", "Thanks to X", "sponsored", "#BrandAmbassador", "my collection", "aff", "sp", "spon", "affiliate". On the word sponsored separately: "Because the term “sponsored” is open to varied interpretation, we advise against using this label to refer to advertising". In the code itself (2.4) there is one example: "for example, by heading them “advertisement feature”" this is the only one of the six jurisdictions where the regulator gives a closed list of suitable and unsuitable words. The quotations are verbatim in English source, checked 2026-08-04

Where it goes. ASA online advice: «The audience should be able to recognise immediately when content is advertising, without having to click or otherwise interact with it»; «It is not, however, acceptable for any disclosure to appear only after clicking “See more” or otherwise clicking on or expanding a post» the wording is close to the FTC rule 16 CFR 465.1(c)(4) on the inadmissibility of a disclosure that requires an action by the user source, checked 2026-08-04

Who is liable. Both the brand and the creator. ASA online advice: "Both brands and influencers are responsible for ensuring that ads are obviously identifiable"; "When a particular “advertorial” is found to breach the CAP Code, both the publisher (i.e., the influencer) and the brand will be named in the ASA ruling". The code section "How the system works": "Marketers bear principal responsibility for the marketing communications they produce and must be able to prove the truth of their claims to the ASA"; "Agencies have an obligation to create marketing communications that are accurate, ethical and neither mislead nor cause serious or widespread offence" the wordings on the responsibility of the marketer and the agency are from the page asa.org.uk/type/non_broadcast/code_section/how-the-system-works.html source, checked 2026-08-04

Penalties. The ASA sanctions page names no monetary fines. Listed are: "Add their name and details of the problem with their advertising to a dedicated section of the ASA website until they comply"; "Ask Search Engines to remove paid-search ads when those ads contain material – or a link to a page on the marketer’s website that contains material – which breaks the rules"; "Place our own paid-search ads to highlight the advertiser’s name and non-compliance"; "Issue Ad Alerts to its media owner members, advising them to withhold services such as access to advertising space"; "Ask its members to revoke, withdraw or temporarily withhold recognition and trading privileges. For example, the Royal Mail can withdraw its bulk mail discount"; "Ask its poster industry members to invoke mandatory pre-vetting for advertisers who have persistently or seriously broken the CAP Code"; "Refer them to other statutory enforcement bodies for the further action, such as Trading Standards" the ASA is a self-regulatory body, there are no monetary sanctions of its own on the page read. The address asa.org.uk/codes-and-rules/sanctions.html returns 404, the working one is /codes-and-rulings/sanctions.html source, checked 2026-08-04

Who it applies to. The code section "How the system works": the Code applies to "marketing communications within the Code’s remit that are commissioned, prepared, placed or published in the UK"; "The Code does not apply to marketing communications in foreign media". The remit page: "The CAP Code also covers “influencer marketing” content appearing on social media, be it in the form of a blog, vlog, tweet, post, story, reel or other channel-specific format"; user content falls under the code when it is "adopted and incorporated" into a marketer's communication, including through "retweeting, commenting on, or even simply “liking” a user’s post". Outside the remit: "Entirely unprompted UGC, where a customer initiates the communication by tweeting to your handle or posting to your timeline, and which the marketer does not endorse" the connecting criterion is the place where the advertising is commissioned, prepared, placed or published; the quotations on the coverage of social media are from the page asa.org.uk/advice-online/remit-social-media.html source, checked 2026-08-04

The document in force. "The UK Code of Non-broadcast Advertising, Direct and Promotional Marketing (the CAP Code)", section 2 "Recognition of marketing communications" (rules 2.1–2.4); the ASA online advice "Recognising ads: Social media and influencer marketing"; the guide "Influencers’ guide to making clear that ads are ads" — the third edition, published on 23 March 2023, the first edition issued by "CAP and the CMA" on 28 September 2018 the edition number of the code and the date it came into force are not stated on the pages read; the marking "v12.2.72" occurs in the names of the code's PDF files on the site, but we did not open a page with the edition number. The guide itself is a PDF, we read its description on the resource page source, checked 2026-08-04

Russia

When it is mandatory. The Federal Law "On Advertising", Article 18.1 part 16: "Advertising distributed in the information and telecommunications network "Internet", with the exception of advertising placed in television programmes and telecasts, radio programmes and radio broadcasts distributed in the information and telecommunications network "Internet", must contain the label "advertising", as well as an indication of the advertiser of such advertising and (or) a site, a page of a site in the information and telecommunications network "Internet" containing information about the advertiser of such advertising". Part 17: "The distribution of advertising and (or) social advertising in the information and telecommunications network "Internet" is permitted on condition that the advertising data operator assigns to the corresponding advertising or social advertising an advertising identifier or a social advertising identifier, which is a unique digital designation intended to ensure the traceability of advertising and (or) social advertising distributed in the information and telecommunications network "Internet" and the recording of information about such advertising and (or) social advertising". Part 3: advertisers, advertising distributors and advertising system operators "are obliged to provide information or to ensure the provision of information about such advertising and (or) social advertising to the federal executive body performing the functions of control and supervision in the sphere of mass media, mass communications, information technologies and communications" we read the version of 38-FZ in force as of 01.07.2026 in the official "Reference Bank of Legal Information" of the GSPI: actual.pravo.gov.ru, document docid 94704, version redid 485984 (the API address actual.pravo.gov.ru:8000/api/ebpi/redtext?bpa=ebpi&t=485984). The site rkn.gov.ru named in the task does not open from this machine — the connection breaks on timeout, as do fas.gov.ru, pravo.gov.ru, gosuslugi.ru Quoted text is our translation from Russian. source, checked 2026-08-04

In what words. The word is set by the law verbatim: the label "advertising" (Article 18.1 part 16). For social advertising — Article 10 part 3.19: "Social advertising distributed in the information and telecommunications network "Internet" must contain the label "Social advertising", as well as an indication of the advertiser of the social advertising and of the site, the page of the site in the information and telecommunications network "Internet" containing information about the advertiser of the social advertising". Besides the word, a digital identifier is required: Article 18.1 part 17 — "The requirements for the advertising identifier, the social advertising identifier, its content, the procedure and time limits for its assignment, its placement when advertising and (or) social advertising is distributed in the information and telecommunications network "Internet", its storage and provision to the federal executive body... are established by the said federal executive body" the law itself gives only the word "advertising" and a reference to an act of Roskomnadzor; the text of the Roskomnadzor order on the requirements for the identifier was not read — rkn.gov.ru is unavailable (a connection timeout). The words "ERIR" and "unified register of internet advertising" do not occur in the text of the law even once; the law speaks of the recording of information by the federal body and of advertising data operators Quoted text is our translation from Russian. source, checked 2026-08-04

Where it goes. There are no requirements as to the place of the label in the text of the law. The procedure for placement is referred to an act of Roskomnadzor — Article 18.1 part 17: "the procedure and time limits for its assignment, its placement when advertising and (or) social advertising is distributed in the information and telecommunications network "Internet", its storage and provision to the federal executive body... are established by the said federal executive body" we searched the full text of 38-FZ (the version as of 01.07.2026): there are no indications of the kind "at the beginning", "before the text is hidden", "in the frame". The subordinate act with the requirements for the placement of the identifier was not read: rkn.gov.ru does not open from this machine Quoted text is our translation from Russian. source, checked 2026-08-04

What you must obtain or register. The law on advertising does not require registration of the creator himself, but it introduces two adjacent bans and one register. Article 5 part 10.6: "The distribution of advertising is not allowed on the personal pages named in part 1.3 of Article 10.6 of Federal Law No. 149-FZ of 27 July 2006 "On information, information technologies and the protection of information" by the users of the information resource who created such personal pages". Article 5 part 10.5: "The distribution of advertising on the information resource of a foreign agent is not allowed". Article 18.1 part 7: the federal body "maintains a register of advertising data operators in the procedure determined by the said federal executive body" we did not read part 1.3 of Article 10.6 of Law 149-FZ (exactly which owners of personal pages fall under the ban and what they must report about themselves to Roskomnadzor) — that is a separate law, and the rkn.gov.ru page with the clarification is unavailable. The words "licence" or "permit" for an advertising distributor were not encountered in the text of 38-FZ Quoted text is our translation from Russian. source, checked 2026-08-04

Who is liable. Article 38 part 7: "The advertising distributor bears responsibility for a breach of the requirements established by... part 16 of Article 18.1... of this Federal Law". Article 38 part 1: "A breach by natural or legal persons of the legislation of the Russian Federation on advertising entails responsibility in accordance with civil legislation". Article 38 part 4: "A breach by advertisers, advertising producers, advertising distributors and the persons named in part 3.13 of Article 10 of this Federal Law of the legislation of the Russian Federation on advertising entails responsibility in accordance with the legislation of the Russian Federation on administrative offences". The obligation to submit information under Article 18.1 part 3 lies on advertisers, advertising distributors and advertising system operators Article 18.1 is not named in the list in part 6 of Article 38 (the advertiser's responsibility); the advertising distributor is responsible for the label "advertising" under part 16. The numbering of the parts in the bank is printed with superscript signs (18 1, 3 13) — we give it in the ordinary form Quoted text is our translation from Russian. source, checked 2026-08-04

Penalties. The Code of Administrative Offences of the Russian Federation, Article 14.3. Part 15 (failure to provide information to Roskomnadzor, breach of the time limits, incomplete or unreliable information): "entails the imposition of an administrative fine on citizens in the amount of from ten thousand to thirty thousand roubles; on officials - from thirty thousand to one hundred thousand roubles; on legal persons - from two hundred thousand to five hundred thousand roubles". Part 16: "The distribution of advertising in the information and telecommunications network "Internet" without an advertising identifier assigned to the corresponding advertising by an advertising data operator, or a breach of the requirements for its placement... entails the imposition of an administrative fine on citizens in the amount of from thirty thousand to one hundred thousand roubles; on officials - from one hundred thousand to two hundred thousand roubles; on legal persons - from two hundred thousand to five hundred thousand roubles". Part 17 (breaches by an advertising data operator): "entails the imposition of an administrative fine on officials - from one hundred thousand to two hundred thousand roubles; on legal persons - from three hundred thousand to seven hundred thousand roubles". Part 1 (the general elements): "on citizens in the amount of from two thousand to two thousand five hundred roubles; on officials - from four thousand to twenty thousand roubles; on legal persons - from one hundred thousand to five hundred thousand roubles" parts 15-17 of Article 14.3 were introduced by Federal Law No. 274-FZ of 24.06.2023. We read the version of the Code of Administrative Offences in force from 26.07.2026 in the same official bank: docid 64282, version redid 495398. The sums are given verbatim, in words, as in the text of the code Quoted text is our translation from Russian. source, checked 2026-08-04

Who it applies to. Article 18.1 part 3: the obligation extends to those who have placed advertising "aimed at attracting the attention of consumers of advertising and (or) social advertising located on the territory of the Russian Federation and meeting the criteria determined by the Government of the Russian Federation". Excluded from the labelling requirement is advertising "placed in television programmes and telecasts, radio programmes and radio broadcasts distributed in the information and telecommunications network "Internet"" (part 16). Separate bans by platform: Article 5 part 10.7 — "The distribution of advertising is not allowed on the information resources of a foreign or international organisation whose activity has been recognised as undesirable on the territory of the Russian Federation... as well as on other information resources access to which is restricted in accordance with the legislation of the Russian Federation on information, information technologies and the protection of information" the connecting criterion is not the creator's place of residence but the aiming at consumers in the Russian Federation; the criteria themselves are established by an act of the Government of the Russian Federation, which we did not read. Part 10.7 of Article 5 was added by Federal Law No. 72-FZ of 07.04.2025, part 10.6 — by the law No. 303-FZ of 08.08.2024 Quoted text is our translation from Russian. source, checked 2026-08-04

The document in force. Federal Law No. 38-FZ of 13 March 2006 "On Advertising", Article 18.1 "Advertising and social advertising in the information and telecommunications network "Internet"" (the article was added by Federal Law No. 347-FZ of 02.07.2021, the title as amended by Federal Law No. 479-FZ of 26.12.2024), the version in force as of 01.07.2026; Article 38 "Responsibility for a breach of the legislation of the Russian Federation on advertising". The Code of the Russian Federation on Administrative Offences No. 195-FZ of 30.12.2001, Article 14.3 "Breach of the legislation on advertising", the version in force from 26.07.2026. The publications of 38-FZ per the bank's card: "Parlamentskaya Gazeta" of 17.03.2006 No. 37; "Rossiyskaya Gazeta" of 15.03.2006 No. 51; Collected Legislation of the Russian Federation, 2006, No. 12, item 1232 in addition, Article 18.2 "Mandatory deductions for the distribution of advertising in the information and telecommunications network "Internet"" has appeared in the law, part 4: the deductions "are established in the amount of three per cent of the base for calculating the mandatory deductions"; the base under part 3 is the quarterly income from services for the distribution of internet advertising aimed at consumers in the Russian Federation. This does not relate to disclosure, but it concerns money and is therefore written down here Quoted text is our translation from Russian. source, checked 2026-08-04

India

When it is mandatory. The ASCI guidelines, § 1: "All advertisements published by social media influencers or their representatives, on such influencers’ accounts must carry a disclosure label that clearly identifies it as an advertisement". § 1.1: "a. Disclosure is required if there is any material connection between the advertiser and the influencer"; "b. Material connection is not limited to monetary compensation. Disclosure is required if there is anything of value given to mention or talk about the advertiser’s product or service"; "c. Disclosures are required even if the evaluations are unbiased or fully originated by the influencer, so long as there is a material connection between the advertiser and influencer"; "d. If there is no material connection and the influencer is telling people about a product or service they bought and happen to like, that is not considered to be an advertisement and no disclosure is required on such posts". The definition: "A material connection is any connection between an advertiser and influencer that may affect the weight or credibility of the representation made by the influencer. Material connection could include, but is not limited to benefits and incentives, such as monetary or other compensation, free products with or without any conditions attached including those received unsolicited, discounts, gifts, contest and sweepstakes entries, trips or hotel stays, media barters, coverage, awards, or any family or employment relationship, etc." we read the PDF of the guidelines from the ASCI site (the text was extracted from the PDF, the quotations are verbatim in English). The same guidelines are reproduced in full in the combined collection ASCI_Codes_Guidelines_Book.pdf, pp. 44-50, and in the designed 2025 version /social/wp-content/uploads/2025/04/ASCI-Influencer-Guidelines.pdf — the text coincides, both are signed "Chairman, Board of Governors, ASCI, August 17th, 2023" source, checked 2026-08-04

In what words. A closed list. § 1.3(a): «Following is the list of disclosure labels permitted. Any one or more can be used: Advertisement; Ad; Sponsored; Collaboration; Partnership; Employee; Free gift; “Paid Partnership” tag on Instagram; Affiliate; “Includes Paid Promotion” tag on YouTube». §1.3(b): «The disclosure should be in English OR in the language as the advertisement itself, in a way that is easy for an average consumer to understand». §1.4: «A virtual influencer must additionally disclose to consumers that they are not interacting with a real human being. This disclosure must be upfront and prominent» the list of ten labels is given in full and verbatim; ASCI directly calls it a list of permitted ones. The words "Sponsored" and "Collaboration", permitted in India, are considered insufficient by the UK's ASA — a direct divergence source, checked 2026-08-04

Where it goes. §1.2: «Disclosure must be upfront and prominent so that it is not missed by an average consumer»; «a. It should be placed in a manner that is hard to miss»; «b. Disclosures are likely to be missed if they appear only on an ABOUT ME or profile page, or bios, at the end of posts or videos, or anywhere that requires a person to click MORE»; «c. Disclosure should not be buried in a group of hashtags or links»; «d. Using a platform’s disclosure tool should be considered in addition to an influencer’s own disclosure»; «e. If the advertisement is only a picture or video post without accompanying text (such as Instagram stories or Snapchat), the disclosure label needs to be superimposed over the picture/video». Duration: «I. For videos that last 15 seconds or lesser, the disclosure label must stay for a minimum of 3 seconds. II. For videos longer than 15 seconds, but less than 2 minutes, the disclosure label should stay for 1/3rd the length of the video. III. For videos which are 2 minutes or longer, the disclosure label must stay for the entire duration of the section in which the promoted brand or its features, benefits etc., are mentioned». «f. In live streams, the disclosure label should be announced at the beginning and the end of the broadcast»; «g. In the case of audio media, the disclosure must be clearly announced at the beginning and at the end of the audio, and before and after every break that is taken in between» the only one of the six jurisdictions that sets the display duration of the disclosure label in seconds and as a share of the video's length source, checked 2026-08-04

What you must obtain or register. For advertising in general it is not required, but for two sectors ASCI requires a qualification and its disclosure. Addendum II (17.08.2023): "Influencers providing advice and/or promoting and/or commenting on merits or demerits on aspects related to commercial goods and services, in the fields of BFSI and Health & Nutrition, must have the necessary qualifications and certifications in order to provide such information and advice to consumers"; "In the area of BFSI related to stock or investments, they should be registered with SEBI and their SEBI registration number should be stated with their name & qualifications. For other financial advice, the influencer must have suitable qualifications such as an IRDAI insurance license, CA, CS etc."; "For posts related to health and nutrition, the influencer must have relevant qualifications such as a medical degree, or be a certified nurse, nutritionist, dietician, physiotherapist, psychologist etc."; "Influencers also must be able to provide proof of such qualifications and certifications should they be asked to by ASCI" there is no requirement in the guidelines for state registration of the advertising itself or for a token, as in Russia; there is a requirement for the creator's qualification in finance and health and for it to be stated in the post. In the 2025 version the following was added: "Influencers who do not have the required qualifications can share generic information about products or services that are not in the nature of technical advice" source, checked 2026-08-04

Who is liable. §1.5: «Responsibility of disclosure of material connection and also of the content of advertisement is upon the advertiser for whose product or service the advertisement is, and also upon the influencer. For clarity, where advertiser has a material connection with the influencer, advertiser’s responsibility will be to ensure that the posted influencer advertisement is in line with the ASCI code and its guidelines. While the influencer shall be responsible for making disclosures required under the guidelines, the advertiser, shall, where needed, call upon the influencer to delete or edit an advertisement or the disclosure label to adhere to the ASCI Code and Guidelines». §2 «Due Diligence»: «The influencers are advised to review and satisfy themselves that the advertiser is in a position to substantiate the claims made in the advertisement» under Addendum I (15.07.2021), if the parties dispute that a post is advertising, ASCI requires "A declaration from the advertiser stating that there is no material connection between them and the influencer as on the date of the post", signed by a senior officer of the advertiser source, checked 2026-08-04

Penalties. ASCI names no monetary sanctions. The ASCI questions and answers page: "The Advertising Standards Council of India (ASCI) will issue a notice to both, the brand owner and influencer for violation of any guidelines"; "Continued non-compliant influencers will find themselves in the list of non-compliant influencers". The ASCI code itself is an act of self-regulation: "This is a self-imposed discipline required under this Code for Self-Regulation in Advertising from all involved in the commissioning, creation, placement or publishing of advertisements". The recognition of the code by the state, per the ASCI collection: rule 7 of the Cable Television Networks Rules, 1994 — "No advertisement which violates the Code for self-regulation in advertising, as adopted by the Advertising Standard Council of India (ASCI), Mumbai, for public exhibition in India, from time to time, shall be carried in the cable service"; "The Department of Consumer Affairs (DoCA) had partnered with ASCI to address all complaints pertaining to misleading advertisements received on Grievances Against Misleading Advertisements (GAMA) portal" there are no amounts of fines on the ASCI pages read, and we do not fill them in ourselves. The state line of liability (the Central Consumer Protection Authority, the consumer protection act of 2019) is not disclosed on the official ASCI pages; the sites of the Indian agencies were not read for this row. The site sections /non-compliance/ and /code-cases/ are closed in ASCI's robots.txt, we did not request them source, checked 2026-08-04

Who it applies to. The ASCI code, the section on responsibility for observance: "This Code applies to advertisements read, heard or viewed in India even if they originate, or are published abroad, as long as they are directed to consumers in India or are exposed to significant number of consumers in India"; "The responsibility for the observance of this Code for Self-Regulation in Advertising lies with all who commission, create, place or publish any advertisement, or assist in the creation or publishing of any advertisement". The period of effect of the guidelines on creators is from the ASCI press release of 27 May 2021: "The guidelines will be applicable to commercial messages or advertisements published on or after June 14, 2021" the wording on the scope is the broadest of the six: it is enough that the advertising is directed at consumers in India or that a significant number of consumers in India have seen it, the place of publication is of no significance. The press release: ascionline.in/wp-content/uploads/2022/09/press-release-influencer-guidelines-2021.pdf source, checked 2026-08-04

The document in force. "Guidelines for Influencer Advertising in Digital Media", Advertising Standards Council of India; the signature "Chairman, Board of Governors, ASCI, August 17th, 2023"; Addendum I of 15.07.2021, Addendum II of 17.08.2023 "For Health and Financial Influencers". The general act is "The Code for Self-Regulation of Advertising Content in India" (the collection ASCI_Codes_Guidelines_Book.pdf, the guidelines on creators are pp. 44-50). The date the guidelines came into force is 14 June 2021 per the ASCI press release of 27 May 2021 ASCI is not a state body but a self-regulatory council; this distinguishes the Indian construction from the Russian and the Chinese and brings it close to the British one source, checked 2026-08-04

Spain

When it is mandatory. The Autocontrol Code, rule 6 "Deber de identificabilidad": "La naturaleza publicitaria de las menciones realizadas por influencers o de los contenidos digitales divulgados por estos, que tengan tal consideración publicitaria, deberá ser identificable para sus destinatarios. En aquellos casos en los que dicha naturaleza publicitaria no sea clara y manifiesta a la vista de la propia mención o contenido, se deberá incluir una indicación explícita, inmediata y adecuada al medio y mensaje, sobre la naturaleza publicitaria de tales menciones o contenidos" (our translation: the advertising nature of mentions and content must be recognisable to their addressees; where that nature is not clear and manifest from the mention or content itself, an explicit, immediate indication appropriate to the medium and the message must be included). Rule 5 counts as consideration "el pago directo (o indirecto a través de agencias), la entrega gratuita de un producto, la entrada gratuita a eventos, la prestación gratuita de un servicio... los enlaces de afiliación, los cheques regalo, las bolsas regalo y los viajes". Law 13/2022, Article 121.3: "Las comunicaciones comerciales audiovisuales deben estar claramente diferenciadas del contenido editorial mediante mecanismos ópticos y/o acústicos y/o espaciales"; Article 122.3 prohibits "la comunicación comercial audiovisual encubierta" our translation, the original is in Spanish; the wordings themselves are given verbatim. The code is the 2025 version, which came into force on 1 October 2025. The text of law 13/2022 was read in the consolidated version on the official BOE portal: boe.es/buscar/act.php?id=BOE-A-2022-11311 source, checked 2026-08-04

In what words. Autocontrol Code, rule 6: «a. A tal fin, se recomienda el uso preferente de los mecanismos ofrecidos por las propias plataformas digitales para identificar un contenido como publicitario. Por ejemplo, “incluye contenido promocional” en YouTube, “contenido promocional” o “colaboración de pago” en TikTok o “colaboración pagada con [marca]” en Instagram. b. Se deben usar indicaciones genéricas claras tales como: “publicidad”, “publi”, “en colaboración con”, “colaboración pagada”, “Embajador de [marca]” o “patrocinado por”. c. Por el contrario, no se deben utilizar indicaciones genéricas o poco claras tales como: “información”, “legal”, “Colab”, “Sponso”, “sp”, “Gracias a [marca]”, “Regalo de [marca]”, “Viaje patrocinado”, etc., o indicaciones en un idioma distinto al de la comunicación tales como “Ad” o “Advertising”. La simple inclusión del hashtag de la marca no será, per se, suficiente para identificar el carácter publicitario del contenido» our translation; the original is in Spanish; the labels are given verbatim in Spanish. A direct divergence from India and the US: the code directly forbids the English "Ad" and "Advertising" in a Spanish-language post, requiring a word in the language of the message itself source, checked 2026-08-04

Where it goes. The Autocontrol Code, rule 6.d: "La indicación relativa a la naturaleza publicitaria de la mención o contenido debe insertarse al inicio del mensaje comercial de forma fácilmente visible. En consecuencia, no serán suficientes aquellas indicaciones que aparezcan mezcladas con otro tipo de información (por ejemplo, junto a otros hashtags) o que requieran una acción por parte del usuario (por ejemplo, hacer clic en “ver más” o “más”)". Rule 6.e: "Cuando el contenido sujeto a este Código se comparta o repostee en otras redes, plataformas o páginas web, la indicación relativa a la naturaleza publicitaria debe mantenerse o añadirse en su caso". The reminder at the end of the code: "El influencer debe asegurar que la indicación del carácter publicitario ofrecida por la plataforma se mantiene cuando el contenido se comparta o repostee" our translation, the original is in Spanish. Annex I of the code gives separate recommendations for each platform and format; the text of the annex contains indications such as "desde el inicio" and a rule for live broadcasts, we give only the general rules so as not to retell the table source, checked 2026-08-04

What you must obtain or register. Yes, for large creators. Law 13/2022, Article 94.4: "Los usuarios de especial relevancia en los servicios de intercambio de vídeo a través de plataforma deberán inscribirse en el Registro estatal de Prestadores de Servicios de Comunicación Audiovisual previsto en el artículo 39". The thresholds are set by Royal Decree 444/2024, Article 3.1: "tendrán la consideración de ingresos significativos, los ingresos brutos devengados en el año natural anterior, iguales o superiores a 300.000 euros, derivados exclusivamente de la actividad de los usuarios en el conjunto de los servicios de intercambio de vídeos a través de plataforma que empleen"; Article 4.1: "a) Que el servicio alcance, en algún momento del año natural anterior, un número de seguidores igual o superior a 1.000.000 en un único servicio de intercambio de vídeos a través de plataforma; o un número de seguidores igual o superior a 2.000.000, de forma agregada... b) Que... se haya publicado o compartido un número de vídeos igual o superior a 24 en el año natural anterior, con independencia de su duración" our translation, the original is in Spanish; the thresholds are given verbatim and must be met simultaneously with the other conditions of Article 94.2 of law 13/2022. This is the second jurisdiction of the six after Russia where there is a state register, but the Spanish register is about the creator's status, not about each advertising message source, checked 2026-08-04

Who is liable. Autocontrol Code, rule 12 «Responsabilidad»: «La responsabilidad por la infracción de lo dispuesto en el presente Código podrá alcanzar a todos los sujetos implicados en la comunicación comercial. No obstante, un sujeto podrá exonerar su responsabilidad si acredita de forma suficiente que la infracción es consecuencia de un incumplimiento puntual y manifiesto de las indicaciones o instrucciones dadas al influencer»; «Cuando se concluya que la mención o contenido promocional ha sido difundido por iniciativa exclusiva del influencer, sin intervención ni relación alguna por parte del anunciante o sus agentes, la responsabilidad, en su caso, podrá ser atribuida en exclusiva al influencer o sus agentes» our translation; the original is in Spanish. The Spanish code is the only one of the six documents read that directly describes release of the advertiser from liability if the creator has broken the instructions given to them source, checked 2026-08-04

Penalties. Two lines. Self-regulation: the code, section A.1 — those who have acceded undertake to "acatar y cumplir de forma inmediata el contenido de las resoluciones que el Jurado de la Publicidad de AUTOCONTROL pueda emitir"; section C.4 — "Las resoluciones serán hechas públicas a través de su inserción en la página web u otros medios de la aea, AUTOCONTROL e IAB Spain"; the code does not establish monetary fines. The law: Article 158.31 classes as serious breaches "El incumplimiento en un período ininterrumpido de un mes de las obligaciones establecidas en el artículo 94 por parte de los usuarios de especial relevancia", Article 159.9 classes as minor ones "El incumplimiento de las obligaciones establecidas en el artículo 94 por parte de los usuarios de especial relevancia que no constituyan infracción grave". Article 160.2 for serious breaches: "multa: 1.º De hasta 30.000 euros para aquellos servicios cuyos ingresos... sean inferiores a dos millones de euros; 2.º De hasta 150.000 euros... 3.º De hasta 300.000 euros... 4.º De hasta el uno coma cinco por ciento de los ingresos devengados en el ejercicio inmediatamente anterior... con un máximo de 750.000 euros". Article 160.1 for very serious ones — up to 60.000, 300.000, 600.000 euros and "hasta el tres por ciento de los ingresos... con un máximo de 1.500.000 euros" our translation, the original is in Spanish; the sums are given verbatim. The steps of the fine are tied to the income from the audiovisual service, not to the gravity of the advertising itself. Supervision is carried out by the National Commission on Markets and Competition (CNMC), as stated in the introduction to the Autocontrol Code source, checked 2026-08-04

Who it applies to. The code is voluntary: section 1 "Ámbito subjetivo": "Las empresas adheridas a la aea, a AUTOCONTROL y a IAB Spain, así como los influencers, las agencias de influencers, las agencias de publicidad y otras empresas que se adhieran al presente Código, se comprometen a cumplir en sus comunicaciones comerciales las normas incluidas en el mismo". The law is tied to the place of establishment: Article 94.2.e of law 13/2022 requires that "El servicio se ofrece a través de redes de comunicaciones electrónicas y está establecido en España de conformidad con el apartado 2 del artículo 3". Article 94.3 takes out from under the obligations educational and scientific centres, museums and theatres, public authorities and parties, businesses and self-employed persons promoting their own goods, as well as associations and non-governmental organisations our translation, the original is in Spanish. Spain is the only one of the six where the law directly requires the creator to be established in the country; in India and the United Kingdom the connection runs to the audience and to the place of publication source, checked 2026-08-04

The document in force. "Código de Conducta de publicidad a través de influencers", a joint act of the Asociación Española de Anunciantes (aea), AUTOCONTROL and IAB Spain, in force from 1 October 2025 (section F: "El presente Código de Conducta entra en vigor el 1 de octubre de 2025"); the first version is from 2020-2021. Ley 13/2022, de 7 de julio, General de Comunicación Audiovisual, Articles 39, 94, 121, 122, 158, 159, 160 (the consolidated version BOE-A-2022-11311). Real Decreto 444/2024, de 30 de abril, "por el que se regulan los requisitos a efectos de ser considerado usuario de especial relevancia de los servicios de intercambio de vídeos a través de plataforma, en desarrollo del artículo 94 de la Ley 13/2022" (BOE-A-2024-8716) our translation, the original is in Spanish. The introduction to the code itself refers to the European Commission guidance 2021/C 526/01 on directive 2005/29/EC — that is, the Spanish rules are built on top of the eu row of this same file source, checked 2026-08-04

UAE

When it is mandatory. The requirement is built not on a label but on a permit. The Council's guide: "The regulatory decision requires all individuals—citizens, residents, or visitors—to obtain the permit before publishing any advertising content on social media for any product, service, event, or activity within the UAE". The conditions for the advertising itself: "Advertisements must be clear and unambiguous"; "Advertisements must not harm the public interest, directly or indirectly"; "Prior approval must be obtained for specialized ads (e.g., real estate, healthcare, finance, education, food, or others as determined by the Council)"; "No false or misleading product information may be published". The permit holder's obligation: "Display the permit number clearly on all social media accounts" we did not find a requirement to label a post with the word "advertising" or an equivalent on the official pages read: we searched in the guide "Guide for the Permit to Regulate Advertising Content on Social Media" and in the list "معايير المحتوى الإعلامي" (media content standards) at nma.gov.ae/ar/uae/media-content-standards — there the talk is of decency, reliability and respect for the state, but not of disclosing the advertising nature. The address uaemediacouncil.gov.ae from the task does not resolve at all; the UAE Media Council is now represented as "الهيئة الوطنية للإعلام" (National Media Authority), the site nma.gov.ae, and the guide lies on cms.nmo.gov.ae source, checked 2026-08-04

Where it goes. The guide, the permit holder's obligations: "Display the permit number clearly on all social media accounts"; "Publish ads only through the account registered with the Council"; "Do not allow third parties to use the registered account for ads" this is about placing the permit number in the account, not about placing a label in a particular post; there are no rules in the document about "before the “more” button", the display duration of the label and the like source, checked 2026-08-04

What you must obtain or register. Yes, a permit is mandatory. The guide: "Scope of Application: The permit applies to all individuals (citizens, residents, visitors) who produce advertising content, with or without compensation, on social media platforms or any modern technological means from within the UAE". The types: "Citizen or Resident Advertiser: Valid for one year, renewable. Visiting Advertiser: Valid for three months, extendable up to six months". The conditions of issue include: "Be fully competent and not less than 18 years old"; "Be of good conduct and not convicted of crimes involving dishonor or breach of trust, unless rehabilitated"; "Not have previously violated media content standards"; "Hold a valid commercial license for electronic media activity from the relevant authority"; "Successfully complete awareness and training programs organized by the Council"; "Have no outstanding financial dues to the Council". The time limits: "The Council reviews the application within three working days after submission of all required documents"; "If no decision is issued within 15 working days from submission, the application is deemed rejected"; "Permits expire 30 days after their validity period if not renewed". The fee per the service page of the National Media Authority: "رسوم الخدمة: أول 3 سنوات بدون رسوم بعدها يتم تحصيل 1000 درهم" (our translation: the first 3 years with no fee, after that 1000 dirhams are charged); "زمن تقديم الخدمة: 3 أيام عمل" the conditions and the time limits are from the Council's English-language guide; the fee and the service term are from the Arabic service page "تصريح معلن للشخص طبيعي لتقديم محتوى إعلاني أو إعلامي في وسائل التواصل الاجتماعي وغيرها من الوسائل التقنية الحديثة (الأفراد)", our translation, the original is in Arabic. In the amount in the fee table of the PDF itself the figures are not extracted: the font has no digit mapping, only the words "Free" and "First 3 years" are visible; therefore the size is taken from the service page. We did not find the date from which the permit became mandatory on the official pages read source, checked 2026-08-04

Who is liable. The guide separates three groups. The permit holder: "Comply with media content standards"; "Verify the identity of advertisers and avoid dealing with fake or anonymous accounts"; "Obtain necessary approvals from relevant authorities where required"; "Submit an annual report of published ads when renewing or upon Council’s request"; "Register for taxation and obtain a Tax Registration Number in line with UAE laws". Advertisers: "Contract only with a permit holder listed in the Council’s public database"; "Ensure the permit holder complies with all conditions"; "Avoid dealing with unauthorized visiting advertisers"; "Sign a written agreement with the advertiser and provide a copy to the Council upon request"; "Preserve national identity and cultural heritage by using Emirati talent or individuals fluent in the Emirati dialect". Agencies: "Agencies must maintain organized records including: Names of contracted permit holders. Copies of advertising content published by them. Detailed information about client entities"; "Records must be retained for 3 years" the UAE is the only one of the six jurisdictions where the advertiser's obligation is formulated as checking the creator's permit against the Council's public database, and the only one where the document requires the involvement of Emirati talent or of individuals fluent in the Emirati dialect source, checked 2026-08-04

Penalties. There are no monetary fines in the guide that was read. Revocation and suspension are named: "The Council may cancel the permit in the following cases (without prejudice to other penalties): Breach of conditions, regulations, or obligations. Publishing advertising content violating approved media standards. Providing inaccurate, falsified, or misleading information in the application. Issuance of a final criminal conviction for felony or crimes of dishonor. At the request of the permit holder (with fee payment), before expiry"; "The Council may suspend the permit temporarily if required in the public interest" the clause "without prejudice to other penalties" refers to other sanctions, but the guide does not give their amounts. We did not read the text of Federal Decree-Law No. 55 of 2023 on media regulation: we did not find an official page with its full text at the accessible addresses, and therefore we do not give the sums source, checked 2026-08-04

Who it applies to. The guide: "The permit applies to all individuals (citizens, residents, visitors) who produce advertising content, with or without compensation, on social media platforms or any modern technological means from within the UAE". The exceptions: "An individual promoting a product or service belonging to themselves or a company they own via their personal account"; "Individuals under 18 years old who produce educational, sports, cultural, or awareness content, provided the activity complies with age classification rules". For visitors: "Visiting advertisers may obtain a permit if registered with a licensed and Council-approved advertising or talent agency"; "The contract between the visiting advertiser and the agency must assign legal responsibility to the agency" the connecting criterion is "from within the UAE", that is the place from which one publishes, not citizenship and not the audience. This is directly opposite to the Indian and the American criterion, where the audience matters and the place of publication is indifferent source, checked 2026-08-04

The document in force. "Guide for the Permit to Regulate Advertising Content on Social Media", UAE Media Council. The legal basis per the guide itself: "The Advertiser Permit is based on: Decision No. (3) of 2025 issued by the Chairman of the UAE Media Council, Federal Decree-Law No. (55) of 2023 on Media Regulation, Related Cabinet Resolutions". The electronic service is "تصريح معلن للشخص طبيعي لتقديم محتوى إعلاني أو إعلامي في وسائل التواصل الاجتماعي وغيرها من الوسائل التقنية الحديثة (الأفراد)" on the portal of the National Media Authority; the application is submitted through eservices.uaemc.gov.ae, as stated in the guide there is no date of issue of the guide in the file itself; the numbers of the decision and of the law are given as the guide names them. We did not read the texts of decision No. 3 of 2025 and of decree-law No. 55 of 2023 — we did not find accessible official pages with their full text source, checked 2026-08-04

China

When it is mandatory. The PRC Law on Advertising, Article 14: "广告应当具有可识别性，能够使消费者辨明其为广告。大众传播媒介不得以新闻报道形式变相发布广告。通过大众传播媒介发布的广告应当显著标明“广告”，与其他非广告信息相区别，不得使消费者产生误解" (our translation: advertising must be recognisable, so that the consumer can tell that it is advertising; the mass media are forbidden to place advertising in the guise of a news report; advertising placed through the mass media must be conspicuously marked with the word "广告" — "advertising" — and be distinguished from other, non-advertising information, without misleading the consumer). The "Measures for the Administration of Internet Advertising", Article 9: "互联网广告应当具有可识别性，能够使消费者辨明其为广告。对于竞价排名的商品或者服务，广告发布者应当显著标明“广告”，与自然搜索结果明显区分。除法律、行政法规禁止发布或者变相发布广告的情形外，通过知识介绍、体验分享、消费测评等形式推销商品或者服务，并附加购物链接等购买方式的，广告发布者应当显著标明“广告”" (our translation: where goods or services are promoted in the form of an account of knowledge, a sharing of experience, a consumer review and the like, with a purchase link attached, the advertising distributor is obliged to mark the publication conspicuously with the word "advertising") our translation, the original is in Chinese; the hieroglyphic wordings are given verbatim. The law was read on the site of the State Administration for Market Regulation (SAMR), the "Measures for the Administration of Internet Advertising" (SAMR order No. 72 of 25.02.2023) — in the Bulletin of the State Council of the PRC: gov.cn/gongbao/2023/issue_10506/202306/content_6885261.html. The wording about "the sharing of experience and consumer reviews with a purchase link" is directly about bloggers' posts source, checked 2026-08-04

In what words. The word is set by the law verbatim: "广告" ("advertising"). The "Guide to Law Enforcement on the Identifiability of Internet Advertising" (SAMR, 22.08.2024), point 6: "广告发布者（或者自行发布广告的广告主，下同）可以通过文字标注、语音提示等方式，增强互联网广告的可识别性。通过文字标注方式的，应当显著标明“广告”。通过语音提示方式的，应当通过清晰的语音提示其为“广告”" (our translation: identifiability may be strengthened by a text label or by a voice notification; with a text label one should conspicuously indicate "advertising", with a voice one clearly notify by voice that this is advertising). Point 14: "互联网广告发布者在显著标明“广告”的同时，鼓励其标明广告发布者身份。对于使用人工智能（AI）技术生成或者深度合成技术制作的广告，鼓励广告发布者作出“本广告使用AI技术”“本广告使用深度合成技术”“本广告由AI技术生成”等提示" (our translation: alongside the label "advertising" the indication of the distributor's identity is encouraged; for advertising created by means of artificial intelligence or of deep synthesis, the labels "AI is used in this advertisement", "deep synthesis technology is used", "this advertisement was created by AI" are encouraged). Point 3: "是否显著标明“广告”，不是广告的判定依据" (our translation: the presence or absence of the label "advertising" does not in itself determine whether a message is advertising) our translation, the original is in Chinese. China is the only one of the six jurisdictions where the regulator writes directly about labelling advertising made by artificial intelligence — though in the form of encouragement, not of an obligation source, checked 2026-08-04

Where it goes. There are no requirements as to the place of the label in the law, there are criteria for recognising advertising as identifiable. The SAMR guide, point 7: "广告发布者、互联网信息服务提供者通过设置专门区域，并显著标明“广告”或者以其他方式明确告知该区域内商业信息均为广告的，可以认定该区域内广告具有可识别性". Point 8: advertising may be recognised as identifiable if "商品经营者或者服务提供者通过自有的网站、网页、互联网应用程序等，对自己所销售的商品或者提供的服务发布广告的" or if the seller publishes it in his own space on a platform "并且利用其账号名称、店铺名称等方式向消费者公开其商品经营者或者服务提供者身份的". Point 9 on live broadcasts: advertising is recognised as identifiable if "直播间运营者或者直播营销人员在直播营销活动中始终显著标明其为商品经营者或者服务提供者，或者消费者可以通过其账号名称识别其上述身份的"; "在直播页面显著标明直播内容为广告的"; "在直播过程中对广告时段的起止点作出显著标明或者明确语音提示的". Point 10 obliges the supervisory authority to pursue, among other things, "在新闻资讯、互联网视听内容等互联网信息内容流中发布广告，未显著标明“广告”的" our translation, the original is in Chinese. For live broadcasts the beginning and the end of the advertising segment have to be marked or clearly announced by voice — the closest analogue of the Indian rule on the duration of the label source, checked 2026-08-04

What you must obtain or register. There is no registration of the creator or of a marking token in the documents read. There is prior vetting of particular sectors and an obligation to keep documents: the "Measures", Article 7 — "发布医疗、药品、医疗器械、农药、兽药、保健食品、特殊医学用途配方食品广告等法律、行政法规规定应当进行审查的广告，应当在发布前由广告审查机关对广告内容进行审查；未经审查，不得发布". Article 14 obliges contractors and distributors "查验并登记广告主的真实身份、地址和有效联系方式等信息，建立广告档案并定期查验更新", the storage period is "自广告发布行为终了之日起不少于三年". Article 16 obliges platforms "记录、保存利用其信息服务发布广告的用户真实身份信息，信息记录保存时间自信息服务提供行为终了之日起不少于三年" our translation, the original is in Chinese. We searched for words about a licence or a permit for the creator in the full text of the "Measures" and of the law on advertising — they are not there; instead of a permit for a person, the law requires the platform to store his genuine data for three years source, checked 2026-08-04

Who is liable. Liability is distributed by the roles defined in Article 2 of the law: 广告主 (the advertiser), 广告经营者 (the contractor), 广告发布者 (the distributor), 广告代言人 (a person who advertises in his own name: "广告主以外的，在广告中以自己的名义或者形象对商品、服务作推荐、证明的自然人、法人或者其他组织"). The distributor is liable for the absence of identifiability: the SAMR guide, § 4 — "互联网广告不具有可识别性的，广告发布者应当依法承担相应的法律责任。广告主自行发布互联网广告的，应当承担广告发布者责任"; § 5 — "互联网平台用户利用平台信息服务发布广告的，该用户是广告发布者". The "Measures", Article 19 on live broadcasts: "商品销售者或者服务提供者通过互联网直播方式推销商品或者服务，构成商业广告的，应当依法承担广告主的责任和义务。直播间运营者接受委托提供广告设计、制作、代理、发布服务的，应当依法承担广告经营者、广告发布者的责任和义务。直播营销人员...以自己的名义或者形象对商品、服务作推荐、证明，构成广告代言的，应当依法承担广告代言人的责任和义务". Article 38 of the law: the person advertising "不得为其未使用过的商品或者未接受过的服务作推荐、证明" our translation, the original is in Chinese. Point 5 of the guide directly calls the platform user an advertising distributor — that is, the blogger is liable not as an "endorser" but as an advertising medium source, checked 2026-08-04

Penalties. The Law on Advertising, Article 59, part 3: "广告违反本法第十四条规定，不具有可识别性的，或者违反本法第十九条规定，变相发布医疗、药品、医疗器械、保健食品广告的，由市场监督管理部门责令改正，对广告发布者处十万元以下的罚款" (our translation: if advertising breaches Article 14 of this law and does not possess identifiability, the market supervision authority orders correction and imposes on the advertising distributor a fine of up to one hundred thousand yuan). The "Measures for the Administration of Internet Advertising", Article 25: "违反本办法第八条、第九条规定... 或者互联网广告不具有可识别性的，依照广告法第五十九条第三款规定予以处罚". For the persons advertising, Article 61 of the law: "由市场监督管理部门没收违法所得，并处违法所得一倍以上二倍以下的罚款" — including for "明知或者应知广告虚假仍在广告中对商品、服务作推荐、证明的". Article 31 of the "Measures": the decisions on punishment are published "通过国家企业信用信息公示系统向社会公示", and in the case of grave breaches the violator is entered in the "严重违法失信名单" our translation, the original is in Chinese; the sums are given verbatim. The SAMR guide, § 13: on a first breach of the identifiability requirements with insignificant consequences and timely correction "可以依法不予行政处罚" — the punishment may not be imposed source, checked 2026-08-04

Who it applies to. The Law on Advertising, Article 2: "在中华人民共和国境内，商品经营者或者服务提供者通过一定媒介和形式直接或者间接地介绍自己所推销的商品或者服务的商业广告活动，适用本法". The "Measures", Article 2: "在中华人民共和国境内，利用网站、网页、互联网应用程序等互联网媒介，以文字、图片、音频、视频或者其他形式，直接或者间接地推销商品或者服务的商业广告活动，适用广告法和本办法的规定" (our translation: on the territory of the PRC the law on advertising and these measures apply to commercial advertising activity through internet media such as sites, pages and internet applications, in text, image, audio, video or other form, directly or indirectly promoting goods or services). Article 20 of the "Measures" determines jurisdiction: "对违法互联网广告实施行政处罚，由广告发布者所在地市场监督管理部门管辖" the connecting criterion is the territory of the PRC; a criterion of "aiming at consumers", as in India or the USA, is not in the text. Separate bans touching SMM: Article 6 of the "Measures" prohibits internet advertising of tobacco, including electronic cigarettes, and of prescription medicines source, checked 2026-08-04

The document in force. The "Law of the People's Republic of China on Advertising" (中华人民共和国广告法), Articles 2, 14, 38, 59, 61 — the text on the site of the State Administration for Market Regulation (国家市场监督管理总局, SAMR). The "Measures for the Administration of Internet Advertising" (互联网广告管理办法), SAMR order No. 72: "《互联网广告管理办法》已经2023年2月24日市场监管总局第3次局务会议通过，现予公布，自2023年5月1日起施行", signed by the head of the administration Luo Wen on 25 February 2023; Article 32: at the same time the "Interim Measures for the Administration of Internet Advertising" (State Administration for Industry and Commerce order No. 87 of 4 July 2016) ceased to have effect. The "Guide to Law Enforcement on the Identifiability of Internet Advertising" (互联网广告可识别性执法指南), announced by SAMR on 22 August 2024, published on the site on 23 August 2024 our translation, the original is in Chinese. The official portal gkml.samr.gov.cn, on which the departmental copy of the "Measures" lies, does not resolve from this machine; the text of the "Measures" is taken from the Bulletin of the State Council of the PRC (gov.cn), the law and the guide from the main site samr.gov.cn source, checked 2026-08-04

What to do

Go by where you live, not by the platform's country. The requirement is addressed to whoever places the advertising.
The label goes at the start, not the end. Almost every regulator agrees on this: a disclosure you have to expand or scroll to does not count as a disclosure.
The platform's rules do not override the law. Встроенная пометка «paid partnership» label satisfies the platform's rules; it does not satisfy every regulator's requirements.
Check the platform's own rules on outbound links — platform restrictions.