Rules and ethics
Part of Private social messages count as electronic mail, and other UK rules for B2B sellers
B2B social selling disclosure policy: first contact
B2B social selling disclosure policy: set a first-contact label, name the reviewer and define how to correct unclear live content.
A B2B social selling disclosure policy tells employees, agencies and commissioned specialists when a commercial relationship must be visible, who selects the label and what happens if a live post is unclear. It should cover English-facing work within a wider UK rule set.
It does not replace advice on whether a particular communication, audience or incentive engages advertising or consumer law.
What to take away
- A disclosure policy must name who selects the label and who can stop publication.
- Record any incentive, including verbal arrangements, in a register before briefing content.
- For trade-facing outreach, identify the sender and commercial role at first contact; use
AdorAdvertfor in-scope advertising where appropriate. - Approval should apply to the published version, not a draft that later gains stronger wording.
- The standard is what the audience can recognise now, not what the team intended.
Define whose content the policy covers
Include company accounts, employee profiles used for authorised promotion, agency work, commissioned experts, referral partners, creators, case studies and testimonials. Name the business owner and the reviewer who can stop publication.
Whose content is covered
- Company accounts
- Employee profiles used for authorised promotion
- Agency work
- Commissioned experts
- Referral partners
- Creators
- Case studies and testimonials
Do not limit the policy to people described as influencers. The CMA's Social media endorsements: being transparent with your followers guidance is for creators, while its Social media endorsements: being transparent with your audience guidance addresses businesses. These are consumer-protection guidance, not a universal statutory label rule for wholly trade-facing contact. For B2B advertising, the Business Protection from Misleading Marketing Regulations 2008 govern misleading advertising directed at traders and comparative advertising; assess the message under those rules as well as the policy's plain-disclosure standard.
Create an incentive and control register
Before briefing content, ask:
Incentive and control register
- Was money, commission, a discount, access, hospitality, a loan or a product offered?
- Does the speaker own, work for or represent the supplier?
- Did the business request, approve or control the message?
- Is an apparently independent experience being used to sell?
Record the answer, value or nature of the relationship, parties, dates and affected material. A verbal arrangement belongs in the register. The CMA's Social media endorsements: being transparent with your audience guidance tells businesses to set disclosure expectations and monitor content posted for the brand.
Choose a label for the first interaction
Define “first interaction” as the earliest campaign item the prospect can see: the connection request if it contains a pitch, otherwise the first direct message; for a public post, the post itself, not a later reply. As a policy rule for trade-facing outreach, identify the sender, employer and commercial purpose in the first visible line—for example, “I work for [Company] and am contacting you about …”. For an in-scope ad or paid endorsement, the creator guidance recommends Ad or Advert before the claim and warns against ambiguous wording such as gifted, affiliate, collab or sponsored. Do not present that consumer-facing guidance as a statutory label mandate for every B2B message, and do not bury a disclosure in hashtags, a biography or content that requires another click.
LinkedIn platform tools can supplement a disclosure. Where available, LinkedIn's Paid partnership label can mark a post with a brand relationship; LinkedIn Brand Partnership Ads are a paid format for promoting an eligible member's post, not a substitute for clear disclosure on a connection request or direct message. Check what the audience sees on the relevant device and format, and decide whether each independently viewed item in a carousel, video or sequence needs its own treatment.
CAP Code section 2 applies where the communication is within its scope. Rule 2.1 requires marketing communications to be obviously identifiable, and rule 2.3 bars falsely claiming or implying that the marketer is acting as a consumer. The ASA administers the Code; its adjudications can lead to an ad being amended or withdrawn through the CAP compliance system. The BPRs can expose a business to criminal enforcement for specified breaches; for consumer-facing material, the Digital Markets, Competition and Consumers Act 2024 gives the CMA direct consumer-law enforcement powers and does not replace the B2B rules.
Add an evidence and approval route
Require the brief to include the relationship record, proposed label, claim evidence, permissions and final placement. The person featured should confirm that an experience is genuine and accurately described. Approval should apply to the published version, not a draft that later gains stronger wording.
Keep employer ownership separate from disclosure. A salesperson may genuinely believe a product claim while also having an employment interest that changes how the audience reads it. A personal-view sentence does not erase that relationship.
Monitor, correct and learn
Assign someone to inspect the live post promptly, including truncated text and reposted formats. If identification is inadequate, pause paid distribution where possible, preserve the original record and correct the disclosure. The CAP Code also requires documentary evidence for objective claims, so a visible label does not cure an unsupported promise.
Log corrections, repeated failures and partner action. Escalate deliberate concealment, complaints or uncertain mixed audiences to a qualified reviewer. Recheck the policy against current CMA guidance and the CAP Code when reviewing each campaign. The standard should be what the audience can recognise now, not what the team intended them to notice.
Before you act
- Name the business owner and the reviewer who can stop publication.
- Record the relationship, value, parties, dates and affected material.
- Define first interaction and require the appropriate disclosure at that point.
- Check what the audience sees on the relevant device and format.
- Inspect the live post promptly, including truncated text and reposted formats.
- Log corrections, repeated failures and partner action.
Common questions
What should a disclosure policy cover beyond company accounts?
It should cover employee profiles used for authorised promotion, agency work, commissioned experts, referral partners, creators, case studies and testimonials. The policy must name the business owner and the reviewer who can stop publication. Do not limit it to people described as influencers.
Why is a label like gifted or sponsored not enough?
The CMA creator guidance recommends Ad or Advert for the consumer-facing endorsements it covers and warns against ambiguous wording such as gifted, affiliate, collab or sponsored. For trade-facing outreach, the policy should identify the sender, employer and commercial purpose at first contact; do not assume the consumer guidance prescribes one label for every B2B message. A platform label can supplement, but not replace, a clear disclosure.
What should happen if a live post has inadequate identification?
Pause paid distribution where possible, preserve the original record and correct the disclosure. The CAP Code also requires documentary evidence for objective claims, so a visible label does not cure an unsupported promise. Log corrections, repeated failures and partner action, and escalate deliberate concealment to a qualified reviewer.
