Strengthening the ASA’s influencer marketing guidance with consumer evidence 

The Advertising Standards Authority (ASA) is the UK’s independent advertising regulator, and a core pillar of its code is that marketing communications must be obviously identifiable as such. For most ad formats context does much of the work, but influencer marketing is different: ads appear within personalised feeds, with no clear break between commercial and organic content, and are designed to feel native. When consumers cannot tell they are being sold to, trust in advertising suffers. 

The ASA’s previous study was in 2019. Since then TikTok and short-form video have grown, platforms have introduced native ad-labelling tools, and consumer media literacy has evolved. The ASA needed fresh evidence to keep its guidance fit for purpose and reflect current consumer expectations and behaviours. 

MTM designed the research around one principle: test consumer understanding in the conditions people actually encounter influencer advertising. The work combined a seven-day online community of 30 participants, eight 60-minute depth interviews, and a nationally representative quantitative experiment with 1,600 UK adults (18 to 64) plus a boost of 300 aged 13 to 17. 

Bespoke mock Instagram and TikTok feeds, built to visually replicate the real platforms, meant recognition could be tested in realistic scrolling conditions and benchmarked against brand ads. A three-layer measurement design captured both instinctive responses (an in-situ ‘Spot the Sell’ scrolling task) and considered responses (post evaluation and label ranking) across four label conditions, from explicit ad labels to ambiguous ones such as ‘#gifted’. 

The research showed influencer ads are significantly harder to identify than brand ads. When tested, 74% of consumers said a brand ad was ‘definitely an ad’, compared with just 54% for influencer ads, a 20-point gap that exposed a real blind spot in consumer self-awareness. 

Labelling proved a critical backstop when contextual signals fail, but only the right labels in the right place. ‘Paid Partnership’, ‘Ad’ and ‘#ad’ were clearest, while ambiguous labels such as ‘#gifted’ and ‘#thanks’ performed no better than no label at all. Placement mattered too, with 79% agreeing labels must appear upfront. Demand for transparency was strong and consistent across every demographic, with 80% agreeing clear labelling is essential. 

The ASA updated its Influencer’s Guide with MTM’s findings on disclosure labels, platform tools and content presentation, giving the regulator a contemporary evidence base for guidance, compliance and enforcement. The work generated significant industry engagement across trade and legal press, around 6,500 LinkedIn impressions, and 1,365 report views with 320 downloads.