Paid adverts

If you have paid for digital material to be published as an advert, then it must have an imprint if it is ‘political material’. This requirement applies to anyone placing a paid advert.

Payment includes payments of any kind – for example ‘pay-per-click’ and ‘pay-per-impression’ advertising.

Payment is not limited to just money. It can also include benefits in kind, for example goods or services being provided for free or at a discount by the promoter to the digital platform hosting the advert.

It does not include payments as part of the costs of creating, setting up, operating or maintaining the material. It is limited to payments made specifically to the service provider or platform hosting the adverts for the publication of those adverts. If the service provider hosting the advert (for example, a digital platform or electronic billboard advertiser) has not been paid for the material to be published on the platform, then the material is not a paid advert.

For example, if you employ a digital agency to pay social media platforms for placing adverts on their platforms, then these are paid adverts because the agency is paying the platforms for the adverts to be published.

By contrast, if you employ a digital agency to publish digital material on their own social media channels, then these are not paid adverts, because the platforms on which the material is published are not being paid. The fact that the agency is being paid does not make the material a paid advert.

Similarly, if you pay an influencer or ambassador to post material on their own social media channels, then these are not paid adverts, because the platforms on which the material is published are not being paid for the material to be published. This is the case even if the posts are classed as adverts for the purposes of other legislation.

Not all payments to the service provider hosting the material will mean the material is a paid advert – only those made to the service provider specifically for the material to be published as an advert.

For example, if you pay a social media company for a certain type of account (e.g. the paid Twitter Blue account on Twitter), this does not make all your posts paid adverts.

By contrast, if you pay a social media company to increase the reach of a post by publishing it as an advert (e.g. boosting a post on Facebook), then this will be a paid advert.

If material is not a paid advert, then it is ‘organic material’. Organic material may still require an imprint – see the section ‘Organic material’.

Last updated: 2 November 2023