TikTok is taking a big swing at disclosure compliance
Sending a strong signal to the market this week, TikTok has begun to enforce branded content disclosure more rigorously. Long available as a workflow on the platform, TikTok One has recently made the process of linking a branded post and toggling on the branded content disclosure much easier, and while clearly stated in their policy guidelines, it remains up to the creator to add the disclosure.
Now, starting on August 20, TikTok will begin tighter branded content disclosure enforcement, starting with a small randomization of accounts before scaling to a majority of accounts within the United States and Thailand on September 1st.
Here’s how it will work. Accounts that post videos TikTok detects as branded content without proper disclosure will receive an in-app notification within 2–3 hours of posting. If the creator doesn't properly disclose or appeal within 24 hours, the content may then be ineligible for the For You page and experience limited traffic distribution, but will remain live and could be shown to followers only.
This marks a new major effort by a social platform to enforce disclosures beyond written guidelines and helpful workflows and will have a significant impact on creator marketing programs at large.
Here’s what you need to know.
What is an Undisclosed Marketing Video, and what constitutes commercial or branded content?
TikTok has coined the term “UMV,” or Undisclosed Marketing Video, as any video that involves commercial branded content but is not clearly labeled as such. That begs the question, what is commercial or branded content?
In creator marketing, the line between commercial and earned content is not always clear. Tactics that include incentive but not a negotiated contract and payout are often viewed as earned or organic media, but not according to regulatory bodies and social platforms.
As a general rule, creator marketing produces branded content–creator content featuring or mentioning a brand, product, or service–which can be truly organic, but is more often than not considered commercial content.
So what makes it commercial content requiring disclosure?
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✅ For TikTok, this means that creators who promote goods or services in return for something of value must disclose it using the proper content disclosure setting as per TikTok's Community Guidelines. |
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✅ Exact legal requirements vary by country. In the United States, the FTC has clear legal requirements through the Consumer Review Fairness Act, with practical guidance for social media influencers outlined as: “A ‘material connection’ to the brand includes a personal, family, or employment relationship or a financial relationship – such as the brand paying you or giving you free or discounted products or services.” - Disclosures 101 for Social Media Influencers |
Moving forward, if you're running creator campaigns on TikTok that involve commercial content, it will be essential to include proper disclosure to avoid delivery disruptions. This includes content like:
✔ Sponsored posts
✔ Gifting, product seeding, or PR
✔ Paid for events and getaways
✔ Promo codes and affiliate inks
Example of the paid partnership label being used on a TikTok video by Justin Doiron (@justine_snacks)
How does TikTok recognize branded content?
TikTok flags videos as branded content when they show clear marketing intent based on three things: financial incentives, brand mentions, and product recommendations.
Financial incentives: This includes any money or benefits received for promoting something like URLs, promo codes, hashtags, collaboration mentions, QR codes, or overlay ads.
Brand mentions: When a brand’s name appears as a hashtag (#brand), a tag (@brand), or their logo shows up.
Product recommendations: Showing or talking about a product or service, like demos, tutorials, or calls to action like "buy now" or "shop today"
TikTok’s system will consider correlations across all three of these factors to determine the likelihood content is branded or commercial.
What does this mean for your TikTok activations?
Consumers value transparency and disclosure. Both brands and creators have found themselves in not only reputational hot water, but legal too, when an undisclosed sponsorship goes awry. On the flip side, creators often get accused of passing off genuine organic fan content as sponsored when it’s not.
When your creators use the "Paid Partnership" disclosure, it helps build trust and maintain an environment where all viewers can clearly see which posts are organic and which are commercial. There have long been rumors that disclosure hurts performance, but TikTok’s decision now means non-disclosure will definitely hurt performance while promising maximum delivery on the For You feed if properly disclosed.
However, this doesn’t mean the impact to your creator activations won’t be great. It might even feel overwhelmingly cumbersome. CreatorIQ is here to help you navigate industry shifts like this as smoothly as possible. Our platform is already integrated with TikTok One and supports an easy content linking workflow for disclosures. Advertisers can send their creators a campaign link within their standard campaign outreach and communication which automatically toggles the Paid Partnership label on, so you can seamlessly manage, monitor, and measure your compliant TikTok strategy.
Image of a TikTok campaign invite link shared via CreatorIQ. When a creator uses this link, the Paid Partnership disclosure is automatically toggled on for them.
Why content linking on TikTok matters:
- Freedom to work with any TikTok creator over 18 without running into community guideline issues.
- Easily stay compliant with paid partnership content rules when creators link their posts through CreatorIQ.
- Bonus performance data! Get aggregated first-party reporting for creator posts.
- Simplify your Spark Ads process with quick authorization and automatic syncing of approved videos to TikTok Ads Manager.
The bottom line: as the creator marketing industry grows up, compliance is becoming increasingly prioritized
The waves of disclosure enforcement will surely be felt over the coming months as TikTok scales this initiative, and time will tell how this affects creator marketing on TikTok, creator and brand relationship management, and if other platforms may choose to follow suit.
What’s clear is that in a time when AI is transforming marketing at large, creator marketing is entering an era of professionalization, and enterprises are shoring up their standards and governance to properly and proactively mitigate risk–instituting more rigor around commercial marketing disclosures makes sense.
In June, CreatorIQ’s Head of Legal, Daniel Hepher, wrote about compliance as a brand advantage:
“Legal compliance in creator marketing is no longer niche. It’s part of the industry’s broader maturation. The same way programmatic advertising evolved with fraud prevention and viewability standards, creator marketing is moving toward more defined legal expectations around authenticity, disclosure, and data stewardship.
This doesn’t need to be a burden. It can be an opportunity. Clearer rules mean clearer expectations—and for brands that take compliance seriously, a chance to differentiate through trust and transparency.”
How does your organization view compliance in your creator marketing strategy? If it’s a box to check, or viewed as a burden, suggestion, or nice-to-have, it may be time to re-evaluate. Compliance guidelines and policies are integral to how you approach risk assessment overall for your program and for your business.
Standardizing your operations for compliance measures based on global guidelines but with platform and regional variances considered can make you better prepared to adapt to industry changes.
Reach out to your Customer Success Partner or CreatorIQ representative to learn more about how CreatorIQ can help you navigate TikTok’s new enforcement without interruption to your campaigns.
And, if you’re a current customer, you can brush up on the campaign linking workflow in CreatorIQ here.