International Affiliate Disclosure: A Comparison
The US, UK, EU, Canada, and Australia all require clear disclosure of paid recommendations. What is universal, what differs, and a single approach that satisfies all five.
Affiliate disclosure is regulated in every major English-speaking market, and the core requirement is remarkably consistent: commercial content must be obviously identifiable as advertising, and paid recommendations must be clearly labeled. What differs is the legal machinery, the acceptable labels, the penalties, and a handful of country-specific rules such as the EU’s paid-ranking disclosure. If you publish to an international audience, you must satisfy the rules of each market you reach.
The comparison at a glance
| Market | Regulator / law | Core requirement | Notable penalty |
|---|---|---|---|
| United States | FTC (Endorsement Guides; Reviews Rule) | Clear and conspicuous disclosure of material connection | Up to $53,088 per violation |
| United Kingdom | ASA/CAP Code; CMA under DMCC Act 2024 | Ads must be “obviously identifiable”; label as “Ad” | CMA fines up to £300k or 10% of global turnover |
| European Union | UCPD; Omnibus Directive; DSA | No hidden advertising; disclose paid rankings | Fines ≥ 4% of turnover for cross-border breaches |
| Canada | Competition Bureau; Competition Act | Disclose material connections; no misleading representation | Corporate: greater of C$10M or 3% of global revenue |
| Australia | ACCC; Australian Consumer Law; AANA Code | Advertising “clearly distinguishable” | ACL penalties for misleading conduct |
What is universal
- A material connection — commission, payment, or free product — must be disclosed.
- Disclosure must be prominent and up front, not buried.
- Vague or coded labels (“#sp,” “#collab,” “#aff”) are rejected everywhere.
- Both the creator and the brand share responsibility.
What differs
- Preferred label: the US accepts “#ad”; the UK strongly prefers the explicit word “Ad” or “Advertisement.”
- Paid ranking: the EU specifically requires disclosing paid placement in search and listing results.
- Language: Canada requires disclosure in the language of the content (English and/or French).
- Enforcement model: the UK’s CMA can now fine directly without going to court.
A practical rule for global publishers
Adopt the strictest common denominator: an explicit, plainly worded disclosure using the word “ad” or “advertisement” (or “I earn a commission”), placed before the recommendation, in the content itself. That single approach satisfies all five markets.
Explore each market: UK ASA/CAP, UK CMA and the DMCC Act, EU UCPD, EU Omnibus Directive, EU DSA, Canada, and Australia.
Last reviewed July 2026. This page is general educational information, not legal or tax advice.