Rules and ethics
Part of Property creators rules and ethics in England
A property creator disclosure policy with labels, relationship records and someone to enforce it
Build a property creator disclosure policy for England with clear labels, relationship records, platform handling, accessibility and correction routes.
What to take away
- Cover paid posts, gift and discount arrangements, affiliate commission, free access and hospitality.
- Put one approved label at the first point of contact and repeat it on every separated asset.
- Record the provider, benefit, dates and expiry for each relationship in one register.
- Name one person accountable for recording, approval, publishing and enforcement.
- In England a missed label can bring an ASA ruling, a referral to Trading Standards and CMA action.
What the policy must cover
The policy should list every relationship that could change how a viewer reads a claim. The property creators compliance guide sets out the advertising, estate-agency, finance and rights duties behind it.
Start with money: payment, commission and affiliate links. Then benefits in kind: gifts, discounts, free access and hospitality.
Add structural ties, including employment, ownership, a family connection and the creator's own property business. Keep editorial work apart from commissioned production, sponsorship, lead collection and financial content.
The CMA's content creator endorsement guidance, updated on 3 September 2025, covers free or discounted products, payment, commission and own-brand promotion. It tells brands to check creator content and act when labelling is wrong.
A short skeleton carries six parts.
- Scope and who it binds.
- Relationship types and register fields.
- Label wording and placement.
- Platform tools beside UK duties.
- Roles, approval and enforcement.
- Correction and review date.
Where and when the label appears
The approved label goes at the first point of contact. A viewer should not have to expand text, follow a link or guess the relationship. Repeat it on each clip, story, repost and separately shared asset.
The ASA's advice on recognising ads on social media expects a prominent upfront "Ad" label for influencer advertising. A platform label can be enough when it is clear and prominent, but an extra label may be needed.
Read whether a property video is an advert before drafting wording, because the duties shift once paid commentary becomes estate-agency work.
Make the label perceivable in the format used: contrast, display time, caption and spoken wording, plus how text behaves when truncated. The government's 2026 draft services code under the Equality Act touches accessible information and is consultation text.
YouTube and TikTok each supply a disclosure setting for declared promotions. Record the setting used and keep the UK legal decision beside it.
Example: a gifted stay and an affiliate link
A creator is offered a two-night stay by a developer to film a new-build. The opening three seconds carry "Ad: gifted stay from [developer]". The caption and spoken introduction repeat that the stay was free.
An affiliate link to a removals firm carries "Ad: affiliate link, we earn commission on bookings". The link follows the label, never leads it.
The register holds one row per relationship.
Gifted stay and affiliate link
| Field | Example entry |
|---|---|
| Provider | [developer name] |
| Recipient | [creator account] |
| Benefit | Two-night stay, gifted, no cash payment |
| Contract | [agreement reference and date] |
| Assets | Reel, caption, pinned comment |
| Approval | Advertising reviewer, [date] |
Who owns and enforces it
The relationship owner records the benefit and holds the contract. The advertising reviewer approves wording and placement. The publisher checks the live asset against the approved version.
A property specialist reviews estate-agency and material-information questions. A named financial-promotion specialist reviews mortgage or investment language.
Because the register depends on contract terms, what a property creator contract should cover explains scope, approval rights and exit clauses.
Privacy, rights, security and accessibility decisions block publication until they are resolved. One named person should be accountable for enforcement, not a shared mailbox.
A label cannot legalise estate-agency work, approve a financial promotion, supply a missing permission or substantiate a property statement.
What enforcement looks like in England
The ASA handles non-broadcast advertising, including influencer content. It publishes rulings that name the advertiser and require the ad to be changed or withdrawn. Because it cannot fine, persistent cases go to Trading Standards.
The Property Ombudsman code requires accurate marketing and can order redress when a listing misleads. Trading Standards can prosecute misleading practices.
Under the Digital Markets, Competition and Consumers Act 2024, the CMA can penalise unfair commercial practices directly. Its published cases show how misleading online conduct is pursued.
Correcting a faulty disclosure
- Pause the asset or replace the label while the post is still live.
- Log the fault, date, platform and evidence in the register.
- Correct, re-label or withdraw the asset and notify the client in writing.
- Review the cause with the relationship owner and retrain where needed.
- Suspend new work with that creator until a test asset passes review.
Common questions
What must a property creator disclosure policy contain?
The relationship types covered, the register fields, the label wording and placement rules, and the named owners for approval and enforcement. It should also say what happens when a label is missed.
Who enforces disclosure rules in England?
The ASA for non-broadcast ads, Trading Standards and the CMA for consumer protection, and The Property Ombudsman for estate-agency conduct. Each can act independently.
What happens if a creator misses a label?
Pause or correct the asset at once and log it in the register. Repeat failures justify suspending new work and can lead to an ASA ruling or a Trading Standards referral.
