What a British recommendation page has to disclose, quoted from the ASA's own advice

If you publish a page that recommends, ranks or links to products and you earn anything when somebody buys, that page is advertising and the United Kingdom advertising code applies to it. The ASA's own advice on affiliate marketing, read at asa.org.uk on 22 October 2026 and dated 22 March 2023 on the page itself, is specific about three things that catch publishers out. Responsibility is shared with the brand. The label has to be visible before the reader meets the link, not at the foot of the page. And several labels publishers believe are enough have already been ruled insufficient by name. This page quotes that advice rather than summarising it. Nothing here is legal advice, and the ASA's own note says the same of its guidance, which states that it "does not constitute legal advice".

Both parties are responsible, not just the publisher

The advice is direct on this point. "Both the business and the affiliate marketer are responsible under the Code, notwithstanding the fact that the ads may have been created solely by the affiliate without any input from the business themselves."

So a brand running an affiliate programme carries code responsibility for how its affiliates label content it never saw. That makes labelling a contract term rather than a request, and it is worth writing into the programme terms with a named person who checks.

The two rules the ASA points at

The advice names the rules. "Rule 2.1 of the CAP Code requires that marketing communications are obviously identifiable as such." It then sets out rule 2.3, under which "marketing communications must not falsely claim or imply that the marketer is acting as a consumer or for purposes outside its trade, business, craft or profession" and "must make clear their commercial intent, if that is not apparent from the context".

Those two together are the whole test for a recommendation page. A reader has to be able to tell that the content is advertising, and the page must not read as the independent opinion of a consumer when it is not.

Where the label goes, which depends on how much of the page is commercial

When the whole page is about products you earn from

The advice states that in that case "the commercial nature of the content should be clear prior to consumer engagement", and that the most straightforward way to do that "is likely to be including an identifier, for example 'Ad', in the title of the blog or article in such a way that it is clear to consumers before they click through to the content, as well as to those reading the content".

Before they click through. A label a reader meets only after arriving has already missed the moment the advice describes.

When only some links are commercial

Here the advice is different and more forgiving. "Where only some of the links are for affiliated products and/or not all the content is 'directly connected' to the supply of those products, it's unlikely that a general identifier, for example 'Ad', would be necessary in the title but content related to affiliated products (and the links themselves) should be identifiable as advertising."

It gives two acceptable patterns. "Placing an identifier such as '(Ad)' before parts of the content that relate to affiliated products is likely to be acceptable, as it would distinguish it from the editorial content." Or "stating clearly at the beginning of the content that asterisks or other equivalent identifiers set out in the article relate to 'advertising'".

The two failures that catch almost everybody

• A disclaimer at the bottom. "A disclaimer of this nature at the bottom of such a post is unlikely to be sufficient because there is the potential that the links and any 'directly connected' claims would not be considered obviously identifiable as advertising at the time they are encountered by the reader."
• The word may. "Similarly, a generic and ambiguous disclaimer which indicates that the author 'may' receive a commission is unlikely to be acceptable, particularly where the specific affiliate content has not been highlighted."

The second one is the most widely copied sentence in commercial publishing. In a ruling the advice cites against Associated Newspapers Ltd trading as MailOnline, dated 21 December 2022, articles were judged to be advertising in their entirety, and a disclaimer at the top was judged insufficient because, in the advice's words, the phrasing "may earn an affiliate commission" was "ambiguous and confusing, because it suggested that they might not receive any payment when, barring errors in the administration of the affiliate arrangement, they would receive commission for purchases made via the links".

The labels that have already been ruled insufficient

The pattern across all four is the same. A reader has to understand the label without being told what it means, and page furniture does not count as labelling content.

Where the editorial boundary sits

Mixed pages are treated proportionately. In news articles, blog posts and vlogs the ASA "may accept that the affiliate advertising content appears alongside content that's genuinely editorial in nature", and then "the CAP Code would only apply to the parts that refer to the affiliate brand and its products, as well as any text that includes an affiliate link, promotional code, or other means by which a new customer or sale can be attributed to a specific affiliate". Short formats get less latitude, because "in shorter media such as social media posts, the ASA is less likely to accept that the affiliate advertising can be separated out from the rest of the content".

The separate layer that is law rather than code

The advertising code is one layer. Consumer protection legislation is another, enforced by different bodies. The Competition and Markets Authority publishes guidance on unfair commercial practices, described on its gov.uk publication page, read 22 October 2026, as "Guidance on business conduct that the law on unfair business-to-consumer trading prohibits under the Digital Markets, Competition and Consumers Act 2024". That page records that the guidance was updated on 18 November 2025 to reflect new guidance on price transparency, and that specific guidance on fake reviews is published alongside it.

That is what the CMA's own page says about its guidance, and no obligation is stated here from the text of the Act, because the legislation site could not be read from the machine this was written on and an unread provision is not a source. A compliance position needs the statutory text and a solicitor, in that order. One narrow part of that Act, and what it requires a British retailer to spell out about price, is worked through in our note on wrong AI prices and the DMCC Act. The wider picture of what the ASA can do and what the CAP Code permits is in our note on UK advertising standards.

A checklist for a British recommendation page

• Decide whether the whole page is commercial or only parts of it, because the labelling answer differs.
• Put the identifier where the reader meets it before the link, and in the title where the page is wholly commercial.
• Use a word a consumer understands without explanation.
• Say how the ranking was produced and whether a commercial relationship affected the order.
• Hold the evidence for every objective product claim before publication.
• Put the labelling obligation in your affiliate and creator contracts, with a named checker.
• Diary a review, because prices, availability and the guidance itself all move.

Questions about disclosure on a British recommendation page

Is a disclosure at the end of the article enough?

The ASA's advice says a disclaimer at the bottom "is unlikely to be sufficient", because the reader meets the links before reaching it. Put the identifier where the commercial content is.

Can we write that we may earn a commission?

The advice singles that wording out as ambiguous, and a ruling it cites found exactly that phrasing insufficient. If you do earn commission, say so rather than saying you may.

Does it apply if an affiliate wrote the content without us?

The advice says both the business and the affiliate marketer are responsible under the Code even where the brand had no input, which is why programme terms and a checking step matter.

What about a ranking with no affiliate links at all?

The labelling rules are about commercial relationships, so a genuinely independent ranking with no commercial interest in the order is a different case. Publishing the criteria anyway is what makes it checkable, and it is the part a reader cares about most.

Does it apply to a business to business page?

Rule 2.1 is about marketing communications being obviously identifiable, not about who the reader is, and the advice makes no business to business exception on this point.

How we apply this to our own ranking pages

We publish comparison pages that put AI Knows Us alongside the tools it competes with, which makes every paragraph above our problem as much as anybody's. Our working rule is to rank on a criterion a reader can check, apply it to ourselves on the same terms, and say plainly where a competitor beats us. We also state the commercial interest on the page rather than at the bottom of it, which is the one habit in this entire piece of guidance that costs nothing and changes how a page reads.