CAP – Compliant advertising is a Snap – marketing on Snapchat

The ASA/CAP have released a post called: Compliant advertising is a Snap – marketing on Snapchat. I have enclosed the text of the link below, but please have a look at the ASA/CAP site as there are lots of things of interest to anyone with an interest in Ethical Marketing.

A multimedia messaging app that deviated from the more established model for social media platforms, Snapchat joined the online social ecosystem in 2011 and offered users a fancy camera, messages that expired and a separate section for branded content.  According to YouGov, it is currently the 7th most popular (and 4th most famous) social media platform, and it offers a variety of interesting and innovative ways to advertise. 

As the rules in the CAP Code are largely media neutral – from Snap ads and brand-owned stories in ‘Discover’, to sponsored geotargeting, lenses and stickers – the same rules and principles that apply in other media are equally applicable to advertising on Snapchat. 

But compliant advertising really is a snap – so here are some of the key principles from ASA rulings to help you with your ads on Snapchat.

Pop an ‘ad’ sticker on your advertising Snapsterpiece

As is true for all the other social media platforms, and indeed all media, advertising on Snapchat – whether it’s a Snap ad between stories, a sponsored lens, a story posted by a brand about a product they sell or influencer or affiliate marketing content – must be obviously identifiable as advertising. 

Most ads within Snapchat’s own ad formats seem likely to be recognised as advertising from the context and labelling applied by Snapchat.  Similarly, stories that have obviously come from a brand profile are generally likely to be recognised as advertising without any additional labelling, but this does rely on it being clear that they’re posting about one of their products.

However, the ASA’s research on labelling influencer marketing found that people really struggle to identify when social media posts by influencers are ads.  This means that stories uploaded by influencers (and others) which either are, or contain, advertising or affiliate marketing, are very likely to need an additional label to distinguish them. 

For example, an advertorial story from Marnie Simpson where she was promoting a teeth whitening brand and had included a ‘swipe up’ direct link to the brand’s shop, was judged not to be sufficiently clear – particularly as Snapchat users who were not already very familiar with Marnie Simpson’s commercial relationships would not be able to determine that the story was advertising from the snap alone.

If it’s not otherwise clear we recommend, as a minimum, that stories and other advertising content include a prominent ‘Ad’ labelMake sure the label isn’t too small or the colour too similar to the background – the rules require advertising to be ‘obviously identifiable’, so if your label isn’t clear your Snap is unlikely to be obviously identifiable as an ad.  If you make a series of Snaps that are all ads, each one should be labelled.

For more detailed guidance on the principles here, see the ‘Influencers’ guide to making clear that ads are ads’. 

Make sure you use the right filters to capture the right audience

Targeting is important, particularly for certain types of content and for advertising of certain products like alcohol, gambling and HFSS foods. 

The ASA will always expect you to use all of the tools available to target appropriately on any platform and to ensure that you have taken all reasonable steps to avoid your ads being seen by someone who, for example due to their age, shouldn’t.  It is not sufficient to rely on self-reported age and you should usually also take into account the type of content that the ad appears around.  Also, as many social media ads can be (and usually are) targeted at a defined set of users, the ASA does not consider it relevant that less than 25% of a total platform audience is under-age, and expects marketers to be taking all reasonable steps to exclude under-age consumers from the targeted audience.

Obviously using none of the tools available is always a risky strategy but you should also be careful to ensure that you’re doing enough when promoting age-restricted products or content.  A Captain Morgan Snapchat lens, that turned the user into a caricature of a pirate and depicted cheering and clinking glasses, was judged to be in breach of the Code when the ASA concluded that they had not taken sufficient steps to ensure that it, as an alcohol ad, was not directed at under-18s.  At the time Snapchat offered age-based targeting that relied on self-reported age and the ASA concluded that this wasn’t sufficient enough when promoting alcohol.  Now you can make use of tools that seek to infer real ages based on actual behaviour and target based on interest and various other factors as well, to help you take additional steps to avoid targeting inappropriate audiences.

Always use a CAP Code lens for your advertising content

From alcohol to gambling and motoring to vaping, there are also plenty of specific rules and prohibitions that apply to different ads and products and these apply equally on Snapchat.  Ads for food or supplement brands, especially those claiming weight loss or other benefits, need to make sure any health or nutrition claims made are authorised on the EU Register and the content follows the other rules in Section 15.  For other health and medical products the rules in Section 12 apply.  The same rules apply to both brand marketing and influencer marketing.

If you’re running a competition or prize draw on Snapchat, make sure you include the most significant terms and conditions that apply and a link to the full terms, and follow the other rules in Section 8.


For more on influencer marketing generally visit to find all of our influencer marketing resources.  Our Copy Advice team are also on hand to provide bespoke advice on any Snapchat campaigns.

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