Our call for evidence: recognition and labelling of online ads

We are calling for evidence on people’s understanding of labels and other identifiers that are intended to indicate that online content is advertising.  Ads that are not obviously identifiable as such have the potential to mislead people and damage trust in advertising.

In recent years advertisers have increasingly used online platforms to reach people in new ways: native and influencer advertising have become commonplace.

As the UK’s advertising regulator we expect it to be obvious to people when they are being advertised to. Broadly speaking, we take native and influencer advertising to mean payment (or payment in kind), and messages controlled, by the brand.  

It’s important for people to know when they’re being advertised to so that they can understand when content is intended to promote a product or brand; and is not a publication’s normal editorial content or an influencer’s genuine independent post.  Sometimes the content and / or context of an ad makes that clear but, where they don’t, it’s important for advertisers to label content clearly and upfront. 

The richness of the online space and the diverse ways in which advertisers use it has led to a variety of means of labelling ads.  We want to find out more about what types of labels allow people to understand that content is advertising. This will help us ensure that we advise and regulate the industry in a way that is in tune both with the realities of how evolving digital platforms work and, most importantly, with people’s expectations and experience.

In order to do that, this year, we will be examining evidence about the labelling and recognition of online ads and, later, commissioning our own research into public understanding.

Today we are inviting stakeholders to submit evidence on how people understand those labels and other identifiers that are intended to indicate that online content is advertising.  We are specifically seeking high quality research and evidence on this topic, which can be submitted to us at [email protected].

We would most welcome evidence on:

•    what level and type of commercial influence over editorial content people expect to be informed about, through an ad label or other identifier 

•    how people interpret specific labels and the extent to which wording, placement, visibility and style might impact on people’s ability to identify an ad. This might be relevant in the following contexts, amongst others:

o    paid-for ads and posts on social media platforms;
o    native content on online news websites;
o    content discovery network ads appearing on news websites, for example, and which drive traffic to other content, including advertising;
o    recommendation engines in online retail environments; and
o    influencer marketing; on social media platforms, blogs and vlogs for example.

•    the extent to which people may differ in their ability to identify ads: including whether some groups are more or less likely able to distinguish advertising from non-advertising content and the reasons for that.  CAP maintains guidance on how online advertising to younger children should be labelled

•    current practices for the labelling of online ads, including national and international examples

We recognise that evidence can take many forms; in some cases there may be independent academic research and in others there may be a survey, public opinion poll or assessment of advertising to specific audiences. Stakeholders may choose to submit existing evidence, secondary analysis or bespoke research. Quantitative and qualitative data might both be useful to us.  While we understand that many will have strong views on this topic, we are interested solely in research evidence, rather than individuals’ views or opinions.

Submissions should be made by Friday 13 April to help inform the approach we take to the public research which we plan to carry out. 

Ultimately this project will report on whether the ASA, through its application of the UK Code of Non-broadcast Advertising, Direct & Promotional Marketing, is getting it right on ad labelling online.  If the evidence suggests that we need to change the way we regulate then we will set out how we intend to achieve that.

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