The situation
An influencer campaign plan with paid, gifted and affiliate posts
A skincare brand is launching a serum with twelve creators in Spain and eight in Poland. Some are paid a fee, some get free products, and some earn commission on a discount code. The agency wants the disclosure rules in the creator brief by Friday, in Spanish and Polish.
The marketing lead needs three answers per country: when a post counts as advertising, how it must be labelled on each platform, and whether the brand is liable when a creator forgets. The rules come from EU law, national law and regulators’ guidance, and the creators will read one page at most.
What the research has to settle
The rules behind the answer
- Hidden advertising is banned outright
- The Unfair Commercial Practices Directive lists, among practices that are always unfair, using editorial content to promote a product where the trader paid for it without making that clear. Disguising commercial intent is misleading more generally.
- Payment is not only money
- Free products, affiliate commission and other benefits can make a post commercial. National authorities apply this in their own guidance and decisions.
- The brand is a trader too
- The brand that commissions the content is a trader under the consumer rules and can be held responsible for hidden advertising alongside the creator. The brief and the contract are where it shows it took care.
- Spain has rules for high-reach creators
- Spain’s audiovisual law places creators above certain reach and income levels under specific obligations, including registration. The research confirms whether each creator falls within them.
How it runs in azta
From the question to the document
The question, as you would type it
Skincare brand running an influencer campaign in Spain and Poland. Creators are paid a fee, receive free products or earn affiliate commission. In each country, when must posts be labelled as advertising, what label is acceptable, and is the brand liable if a creator does not disclose?
You start with
An influencer campaign plan with paid, gifted and affiliate posts
- 01
Describe the campaign
Give the countries, the platforms and how each creator is rewarded. azta searches the Unfair Commercial Practices Directive and the Spanish and Polish law.
Cited research· Free - 02
Read the national provisions
Open the Spanish audiovisual provisions and the Polish unfair-practices act in the reader, in the original language.
Atlas statute reader - 03
Write the creator brief
Ask for a one-page brief per country with what to label, how and where. Edit it in Canvas and translate it into Spanish or Polish.
Canvas · Ask azta· Pro - 04
Send it to the agency
Export the brief to Word for the agency, with the internal note on liability kept separately for the file.
Word export· Pro You send
Disclosure rules for the creator brief, per country
What you get
Disclosure rules for the creator brief, per country
Creator brief · draft
Disclosure rules for the serum launch
Every post about the serum is advertising. This applies whether you are paid a fee, received the product free or earn commission on your code. Label it clearly at the start of the post, in the language of the post, and use the platform’s paid-partnership tool where there is one.
Use a clear label. Use the plain word for advertising in the language of the post. A label hidden among hashtags, or only in the comments, is not enough.
Check before posting. Send each post to the agency for review before it goes live, and make no claims about the serum beyond the approved claims list.
Outcomes on your numbers
What azta is worth on this task
Pro pays for itself after
22 minutes a month
At €75 an hour, that is all the time Pro (€27 a month) has to take off your desk to cover its price.
Example figures. Replace them with your own.
- Hours back a year
- 22
- Capacity at your rate
- €1,620
- More creator disclosure briefs a quarter
- 1.5
- Return on Pro
- 5×
- Research
- Drafting
- Your review
A scenario you set, not a promise. The hours that come back go to another client, or deeper into this one.
Want these numbers on your team’s real workload?
Book a demoWhat stays with you
- Regulators’ labelling guidance, which azta does not hold for every country.
- The creator contracts and approval process.
- Product claims, which follow cosmetics rules of their own.
Frequently asked questions
- Does azta hold the regulators’ influencer guidance?
- It holds EU law and national legislation, and some regulator material. Guidance is not held for every country, and azta says what it cites so you can see what still needs checking.
- Does this cover claims about the product?
- No, that is a separate question. Cosmetics claims follow their own EU rules. Ask about them separately.
- Can the brief be translated?
- Yes. In Canvas, select the text and translate it into Spanish or Polish. Have a native speaker check it before it goes to creators.
