Checklist on KKV’s guidelines on the labelling of influencer marketing

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The Finnish Competition and Consumer Authority’s (KKV) guidelines on the labelling of influencer marketing have recently raised a lot of questions and conversations. Precise regulation may seem difficult to adhere to, but it is really just a reflection of the way the industry is evolving.

“The influencer marketing industry has grown rapidly in recent years. We in the industry have been waiting for updated guidelines from KKV to clarify and harmonise practices, as the previous guidelines dated back to 2019. Although the guidelines are now up to date, the jungle of labels can still seem confusing to the individual influencer – especially if you are new to the industry. But don’t worry, we’ve compiled the main points in a clear checklist format.”

Johanna Risku, Production Director

COMMERCIAL PARTNERSHIPS

  • All collaborative content should be labelled as promotional content, regardless of whether you receive money, a product or a service in return.
  • The label must always be present at the beginning of the publication, visible at first glance and remain visible throughout the viewing of the content, regardless of the channel and content. The label should stand out clearly from the background.

For example:
“Advertisement [company X]”

or

For example:
“Commercial cooperation [company X]”

  • When content is targeted to minors (or it is likely that the consumers of the content are otherwise largely minors), always use the term “advertisement”.
  • The marking must be made in the language in which the content was produced.
  • If the publication contains marketing by more than one company, the name of all the companies being advertised must appear on the advertising label.
  • The responsibility for labelling lies with both the company advertising and the influencer. Not only social media content creators are considered influencers, but also other people who create content for promotional purposes (e.g. actors, artists and athletes).
  • If an influencer advertises a product or service of their own company on their personal account and not on the company’s account, this content is considered advertising.
  • If an influencer’s profile contains a link to a company’s channels, the link must also be preceded by an advertising tag. If the profile contains a link to a webpage that contains several advertising links (e.g. Linktree), the advertising labels must be placed next to the advertising links on the webpage.
  • In Instagram and TikTok stories, as well as in promotional content on Snapchat, if the content is a video that is an audio description of a product or service being advertised, the first audio track of such a video must begin with the words “advertisement OR commercial partnership with company X.

For example:
“Advertising link: www.companyx.fi”

PR, PRODUCTS RECEIVED AND EVENTS

  • Even if the influencer has not been paid or obliged to make a publication about a product or service received from a brand or company, publications presenting products or services received are considered advertising. Publications are not considered independent from the company or brand that gifted the products or services, because the influencer receives a monetary benefit that can influence the publications made about the products or services. All PR events and products should always be labelled as advertising.
  • When you present a gift/service/benefit you have received in your content, the label must use either the word “advertisement” or the phrase “received for promotional purposes” and the company that is the subject of the advertisement.

For example:
“Advertisement/product received from [company X]”.

  • Of course, you can specify that the product has been received without a posting obligation.
  • The label must indicate the company that provided the product/service, not the PR agency from which you received the product.
  • If your content features more than one company’s promotional product, all of these companies must be listed in the content. It is therefore not sufficient to say “some of the products were obtained for advertising purposes”, but the content must clearly indicate which products were obtained and from which company.
  • The same rules apply to events organised by companies for promotional purposes, such as PR events, launches, invitations and press days.

For example:
“Advertising/PR [Company X]”

  • The product received does not need to be marked as an advertisement in content where the product is only shown in the background and not presented. In practical terms, if the company or brand is not mentioned or linked to, it does not need to be mentioned.
  • Supporting or secondary products (such as a bouquet of flowers that came with a PR send-out) do not need to be labelled as advertising with the company in question. Only the brand that gave you the gift needs to be labelled.
  • If several companies or brands are being promoted at the same event, the influencer must include all the companies that are highlighted in the publication.
  • Earned content refers to content made in connection with an existing (past, present or future) collaboration but in addition to the agreed upon content. Earned content must also be tagged as advertising with that company.

For example:
“Advertisement/[brand X] coming soon”

or

“I have previously advertised with [company X/brand X]”

or

“An advertising campaign with [company X/brand X] is running,
this publication has not been agreed.”

  • If an influencer shares an image of a comment/post from a follower on Instagram Stories that is related to a commercial campaign or content, this content must be tagged as an advertisement with the company.
  • Affiliate links* in organic content must be marked as advertising with that company. For example, you can use the phrase

For example:
“Advertising link [company X]”

* a so-called affiliate link, which allows the influencer to direct the user to an online shop from their own content and receive a commission if a user then makes a purchase.

KKV GUIDELINES AND FAQ

You can read the full guidelines on the KKV website:
https://www.kkv.fi/kuluttaja-asiat/tietoa-ja-ohjeita-yrityksille/kuluttaja-asiamiehen-linjaukset/vaikuttajamarkkinointi-sosiaalisessa-mediassa/

KKV has collected the most frequently asked questions on its website:
https://www.kkv.fi/kuluttaja-asiat/tietoa-ja-ohjeita-yrityksille/kuluttaja-asiamie[…]et/questions-and-answers-about-impact-marketing-policy

When working with Asennemedia, we always provide guidance on correct labelling and other aspects of content creation. Correct labelling increases the transparency of advertising, which benefits the whole industry as the amount of influencer marketing grows tremendously every year. We want to build an industry where consumers are not misled and where we act as responsibly as possible.