General information, not legal advice. This chapter summarises published regulator guidance in plain language. For a decision that matters, read the cited documents and talk to a qualified adviser.
How to use this checklist
This checklist turns the earlier chapters into twenty questions to answer before an article, newsletter, post or video with an affiliate link is published. It is a memory aid, not a legal test: answering yes to every question does not guarantee that a piece complies with any rule, and a single no does not automatically mean it breaks one. The cited documents are the authority, and the chapter for each group explains the reasoning.
Work through it once when you set up a template or format, and then more quickly for each new piece. Most questions take seconds once the habits are in place.
A. The relationship
Chapters 01 to 03 explain why these questions come first: a disclosure can only be accurate if you know what you are disclosing.
- Do I earn anything if readers click or buy? Commission, a fee per lead, a payment per click or a flat placement fee all count.
- Did I receive anything else connected with this piece? Free or discounted products, loans, early access, trips, prize entries or other benefits are connections too, according to FTC, ASA and CMA guidance alike.
- Is there any business, employment, family or personal tie to the seller? The FTC's Endorsement Guides list these as possible material connections.
- Would an ordinary reader already expect this connection? If not, it needs disclosing. If in doubt, assume they would not.
B. The label
Chapters 02 to 04 cover what a disclosure should say.
- Does the wording say what the connection is, in plain words? For example, that you earn a commission, or that the product was given to you. The FTC's FAQ treats this kind of plain statement as adequate.
- For UK audiences, is the content clearly identifiable as advertising? The ASA's influencer guide recommends a clear upfront label such as "Ad" for affiliate content.
- Have I avoided jargon, abbreviations and vague thanks? Terms ordinary readers might not understand do not inform them.
- Is the disclosure in the same language as the content? The FTC's definition of clear and conspicuous asks for this.
C. Placement
Chapter 04 covers placement by format.
- Will people see the disclosure before they click or decide? At the top of an article, at the start of a caption or at the start of a video.
- Is it close to the links or recommendations it relates to? On long pages, repeat it near later clusters of links and buy buttons.
- Is it visible without scrolling, tapping "more" or opening a description? A disclosure only in a footer, profile, bio or video description is easily missed.
- Does it stand out? Readable size and normal contrast, not pale or tiny text, and not lost in a block of hashtags.
- For video, audio or live content, is it in the content itself? Spoken and shown, and repeated during live streams.
- Have I checked it on a phone? Layouts change on small screens; a disclosure that sits beside the text on a desktop can move to the bottom on mobile.
D. Links
Chapter 05 covers link attributes.
- Does every affiliate link carry
rel="sponsored", or at leastrel="nofollow"? Google's documentation asks for paid links to be qualified. - Is the attribute set automatically by the template or link tool? Manual attributes are easy to forget.
- Are links that exist because of a gift or other benefit treated as paid? Google's link spam examples include links given in return for free products.
E. The content itself
Chapter 06 covers honesty in reviews and endorsements.
- Is every statement about using or testing the product true? If you say or imply you used it, you must have. Say which products you tested and which you researched.
- Does the verdict reflect my honest opinion, including drawbacks? The commission should not decide the ranking or the conclusion, and if payment affects the order of a list, say so.
- Does the piece add something the merchant's own page does not? Original assessment, comparison or evidence, rather than copied descriptions, is what makes affiliate content worth reading.
Example (invented)
A newsletter writer checks a weekly issue against the list. The issue has three affiliate links and one product sent free. Questions 1 and 2 are yes, so the issue opens with "Ad: I earn commission on some links below, and one product was sent to me free; each is marked." Each item is marked next to its link, and the newsletter platform's link settings already add rel="sponsored" to the archived web version.
For merchants and programme managers
The FTC's Endorsement Guides say advertisers can be responsible for what their endorsers publish, and the CMA's guidance says brands share responsibility for labelling. If you run an affiliate programme, a few further questions apply:
- Do the programme terms tell publishers to disclose the relationship clearly, and avoid anything that discourages it?
- Do briefs and creative assets avoid asking publishers to present paid content as independent opinion?
- Is any reward tied to the existence of content rather than to a positive verdict? The FTC's review rule prohibits incentives conditioned on a particular sentiment.
- Is there a routine for checking a sample of affiliate content and following up when a disclosure is missing?
When the answer is unclear
Some situations are genuinely unclear: an old post that predates an affiliate deal, a passing mention of a product, or content seen in several countries. When a question cannot be answered confidently, two rules of thumb follow from the regulators' approach. First, disclosing a connection that turns out not to have needed it does no harm, while leaving out one that did can mislead readers. Second, for anything with real consequences, read the cited documents themselves and take qualified advice rather than relying on a summary, including this one.
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