Marketing Trends

ASCI influencer guidelines: the disclosure and due diligence checklist every brand should run before a collaboration goes live

In India the brand shares responsibility with the influencer for every sponsored post. Here is what ASCI actually requires, and a contract and checklist you can use this week.

A ring light and smartphone on a tripod in a dim studio corner with a ribboned gift box and a closed blank notebook on a wooden table

Key takeaways

  • ASCI holds both the advertiser and the influencer responsible for disclosure and content, so a brand cannot hand the risk to the creator.
  • Disclosure must be upfront and prominent. A tag buried in a hashtag group, a bio or behind a "more" click is likely to be missed and does not count.
  • A free product or perk is a material connection. If a gift was sent, the post needs a label even when the opinion is genuine.
  • Technical advice on investing, insurance or health needs qualifications that are declared upfront. Generic promotion does not, per the April 2025 update.
  • Put the checklist in your brief and your contract, and keep a record of every approved post.

The short version: what ASCI expects from brands

The Advertising Standards Council of India (ASCI) requires every influencer post with a material connection to a brand to carry a clear, prominent disclosure, and it holds the advertiser and the influencer jointly responsible for that disclosure and for the claims in the post. A brand that briefs a creator, sends product or pays a fee therefore needs a written process for labels, claims and approvals, not just a good relationship with the creator.

Who this is for: founders, CMOs and brand managers who are about to spend on creators and want to know what a safe collaboration looks like. The decision is simple: do we have a process that makes every post compliant before it goes live? This article gives you the rules, the contract clauses and a checklist.

The rules below come from ASCI's own Code and Guidelines page, its 28 April 2025 press release and the Central Consumer Protection Authority's 2022 endorsement guidelines as summarised by AZB & Partners. ASCI is a self-regulatory body, and the consumer protection law sits alongside it. This is a practical summary, not legal advice, so have your lawyer review contracts for regulated categories.

Two layers of rules: ASCI and consumer law

Most brands think only about ASCI. There are two layers, and it helps to see both.

  • ASCI's Influencer Advertising Guidelines. A self-regulatory code that ASCI applies to complaints across media, including social media. ASCI can ask for a post to be changed or removed and publishes its findings.
  • Consumer protection law. The Central Consumer Protection Authority issued its Guidelines for Prevention of Misleading Advertisements and Endorsements for Misleading Advertisements on 9 June 2022 under Section 18 of the Consumer Protection Act, 2019, effective 10 June 2022. AZB's summary notes that they cover due diligence for endorsements and require disclosure of a material connection that the audience would not reasonably expect.

The practical lesson is the same in both: if there is a relationship between the brand and the creator, the audience must be able to see it, and the claims must be true.

When a disclosure is required

ASCI defines a material connection as any connection between the advertiser and the influencer that may affect the weight or credibility of the influencer's representation. That includes payment, but also benefits, incentives, and family or employment relationships.

SituationDisclosure needed?Why
Paid collaborationYesClear material connection.
Free product sent, no feeYesASCI says free or discounted products and perks count, even if unsolicited.
Genuine review of a gifted productYesA fair opinion does not remove the connection.
Affiliate link or commissionYes"Affiliate" is a listed label.
Employee or founder posting about the companyYes"Employee" is a listed label.
Influencer bought the product and likes it, no relationshipNoNo material connection exists.

If you are unsure, disclose. A label costs a little reach at worst. A missing label costs a complaint, a takedown and a dent in trust.

Labels, placement and duration

Accepted labels

ASCI's list of labels is: Advertisement, Ad, Sponsored, Collaboration, Partnership, Employee, Free gift, Affiliate, or a platform disclosure tool for material connections. Any one or more may be used, and the label must be understandable to an average consumer, in English or the language of the post. The page does not list vague terms as accepted labels, so prefer the plain word "Ad" or "Sponsored" over something clever.

Upfront and prominent

The disclosure must be where it is hard to miss. ASCI says disclosures in an About Me page, a bio, at the end of a post or video, or behind a "more" click are likely to be missed, and that a disclosure should not be buried in a group of hashtags or links.

Duration and format rules

FormatWhat ASCI requires
Image or video-only post (including stories)Superimpose the label on the visual.
Video of 15 seconds or lessLabel on screen for at least 3 seconds.
Video over 15 seconds and under 2 minutesLabel on screen for one third of the video's length.
Video of 2 minutes or moreLabel on screen for the whole section where the brand or its features are discussed.
Live streamAnnounce the label at the start and the end. If the stream stays visible afterwards, add the disclosure to the caption.
Audio contentAnnounce at the beginning and end, and before and after every break.
Virtual influencerState upfront and prominently that people are not interacting with a real human, as well as the ad disclosure.

For a typical 20 second Reel, that means the label should sit on screen for roughly a third of the clip, not flash for a frame. Brief editors accordingly, and see our guide to Reels for business for how to plan short video production.

Claims, due diligence and who is a "celebrity"

Disclosure is half the story. The other half is whether what the influencer says is true.

  • ASCI advises influencers to satisfy themselves that the advertiser can substantiate the claims in the ad. As the brand, that means you should be ready to hand over proof (test reports, certificates, licence numbers) before the creator posts.
  • In August 2023, ASCI widened its definition of a celebrity so that large influencers fall under the code that applies to celebrity endorsers, as MN4U reported on 9 August 2023. The reported thresholds are about 5 lakh followers on a single account, or annual income above Rs 40 lakh from campaigns. Check ASCI's current text before you rely on a number.
  • For those larger creators, endorsements must reflect a genuine, recent opinion based on adequate information or experience, and due diligence on claims is expected, with evidence available if asked. An advertiser can show that an ad was developed using ASCI's advertising advice as an alternative route.

The takeaway for a brand: never ask a creator to say something you cannot prove, and never let a script promise an outcome ("lose 5 kg in a month", "guaranteed returns") that you have no evidence for. Our guide to marketing metrics helps you separate what you can measure from what you can only hope.

Health, nutrition and finance creators: the March 2025 addendum

ASCI added Addendum II on 6 March 2025 for influencers in banking, financial services and insurance (BFSI) and health and nutrition, and clarified it in a press release dated 28 April 2025.

  • Technical advice needs qualifications. For stock or investment advice, ASCI expects the influencer to be SEBI registered and to state the registration number with their name and qualifications. For other financial advice, suitable qualifications such as an IRDAI insurance licence, CA or CS are expected. For health and nutrition, relevant qualifications such as a medical degree, or certification as a nurse, nutritionist, dietitian, physiotherapist or psychologist, depending on the advice.
  • Qualifications must be declared upfront. Superimposed on visuals or stated as the opening remark in a video, before the reader has to scroll in a text post, and at the start of audio content.
  • Generic promotion is different. The April 2025 press release says qualifications are needed only where technical information and advice are provided. It gives two examples of generic promotion that does not need them: an insurer using an influencer to talk about annual health check-ups, and a health food company tying up with a chef or food blogger to promote a meal service.

If you sell supplements, fitness programmes, courses on investing or financial products, treat this as a gate in your creator selection, not a line in the contract. Our gym marketing guide covers how fitness brands can promote responsibly.

Who is responsible: the brand-side duties

ASCI states that both the advertiser and the influencer are responsible for the disclosure and the content of the ad. The advertiser must make sure posts follow the ASCI Code, and may ask the influencer to delete or edit content or labels. Two addenda help when there is a dispute about whether a connection existed.

  • Addendum 1 (15 July 2021) lets an advertiser dispute a material connection with a signed declaration from a senior representative, such as the Marketing, Legal or Compliance head, saying there was no connection on the date of the post. Where the advertiser is hard to trace or several advertisers appear, proof of purchase from the influencer may be accepted.

That is a useful reminder of why records matter: you may need to show what you sent, what you agreed and what you approved.

The pre-publish checklist (copy this into your brief)

This is an original working checklist built from the rules above. Use it as a one page sign-off sheet for every post.

#CheckPass when
1Material connection identifiedFee, free product, affiliate, employment or family link is recorded in the brief.
2Label chosenA listed label such as Ad, Sponsored, Partnership or Free gift is specified in plain language.
3Label placementSuperimposed or in the opening lines, never only in a hashtag cluster, bio or "more" section.
4Label durationMeets the 3 seconds, one third or whole-section rule for the video length.
5Claims substantiatedEvery product claim has proof on file before the script is approved.
6Regulated categoryHealth, nutrition, investing or insurance advice comes only from a qualified creator who states it upfront.
7AuthenticityThe creator has used the product, or the script does not pretend they have.
8Approval and recordFinal post reviewed against this list, with screenshots and the live link stored.
9Edit rightContract lets you require edits or removal within a set number of hours.

Contract clauses to add this week

  1. Disclosure clause. The creator will use the label and placement set out in the brief for every post and story.
  2. Claims clause. The creator will use only claims in the approved script and will not add health, income or performance promises.
  3. Qualification clause. For regulated categories, the creator confirms qualifications and registration numbers and will declare them upfront.
  4. Approval clause. Posts go live only after written approval, and the brand may require edits or removal.
  5. Record clause. The creator keeps and shares the analytics, the final post and any proof of purchase if requested.
  6. Re-use clause. If the brand turns the post into a paid ad, the label stays visible in the ad.

Have your lawyer adapt these. If you also collect leads from a creator campaign, remember that the data you capture falls under the DPDP Rules timeline too.

A worked example: a skincare launch with ten creators

This is a hypothetical, with labelled assumptions, to show the process rather than a real client result. A D2C skincare brand sends product to ten creators, pays three of them and plans to boost the best two posts as ads.

  1. Connection. All ten have a material connection (free product), so all ten need a label. The three paid creators use "Ad". The seven gifted creators use "Free gift".
  2. Claims. The brand allows only claims it has test reports for. "Dermatologist tested" stays only if the report exists. "Removes pigmentation in 7 days" is dropped.
  3. Medical advice. No creator is allowed to give treatment advice. If a dermatologist is brought in to talk about skin conditions, their qualification appears upfront.
  4. Timing. Each 30 second Reel carries the label for at least one third of its length.
  5. Boosting. When the two best posts become ads, the label stays on the ad.
  6. Record. The marketing manager stores the brief, approval email and live links for all ten.

Total extra effort: a one page brief and about fifteen minutes of review per post. Compare that with a takedown during a launch week.

Your next seven days

  1. Day 1. List every creator, ambassador and affiliate you work with, and mark their connection.
  2. Day 2. Audit live posts against the checklist and ask for edits where labels are buried.
  3. Day 3. Add the clauses above to your template agreement.
  4. Day 4. Build the claims file: proof for every statement in your scripts.
  5. Day 5. Review regulated categories and remove unqualified advice.
  6. Day 6. Brief your agency and editors on label duration.
  7. Day 7. Save the checklist in a shared folder and make it a standing step in every campaign.

Always read ASCI's current guidelines page before a major campaign, because the text is updated from time to time. This article reflects the page as read on 14 October 2026.

Frequently asked questions

What are the ASCI influencer guidelines?

They are ASCI's rules for advertising by influencers on social media. They require a clear disclosure of any material connection between the brand and the influencer, set how long and where the label must appear, and add extra rules for health and finance advice.

Which disclosure labels does ASCI accept?

ASCI lists Advertisement, Ad, Sponsored, Collaboration, Partnership, Employee, Free gift and Affiliate, or a platform disclosure tool for material connections. The label must be understandable to an average consumer and not buried among other hashtags or links.

Do I need to disclose a free product?

Yes. ASCI says a material connection is not limited to payment. Free or discounted products and perks given to an influencer require disclosure, even if the gift was unsolicited and the review is entirely the influencer's own view.

Who is responsible if an influencer post breaks the rules, the brand or the influencer?

Both. ASCI states that the advertiser and the influencer are each responsible for disclosure and ad content, and the advertiser may ask the influencer to delete or edit the post or the label.

Can any influencer talk about investments or health products?

Not if they give technical advice. For stock or investment advice ASCI expects SEBI registration, and for health and nutrition advice a relevant qualification, declared prominently upfront. Generic promotions that are not technical advice do not need those qualifications.

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