Influencer advertising and AGCOM 2026: ADV checklist before you publish

A reel can look spontaneous and still be advertising. The brand does not need to have paid a large sum: a product you received, a hotel night, an invitation, a service, an affiliate link or a discount code can all count. So the useful question before publishing is not “how much did I earn?” but “is there a benefit linked to the visibility I am giving?”.

This guide turns the AGCOM operational FAQ, published on 16 March 2026, into a practical checklist for creators with a community of between 10,000 and 500,000 followers. It is informational material, not legal advice. The rules may change and each case must be assessed in its own context: before a sensitive campaign, always check the latest version of the official sources and seek professional advice if you are in doubt.

The 500,000-follower threshold is not a free-for-all

AGCOM defines a “relevant influencer” as someone who reaches at least 500,000 followers or one million average monthly views on at least one platform. For views, the average of the previous six months is used; for followers, the figure recorded thirty days before the notification. Exceeding the threshold on a single platform extends the framework for relevant influencers to the other accounts used as well.

Among other things, these thresholds identify who must register in the AGCOM Register and comply with the specific requirements of the Guidelines and the Code of Conduct. They do not mean, however, that below 500,000 followers advertising can be hidden. The FAQ expressly invite creators below the threshold to comply with advertising transparency, fair commercial communications, protection of minors and fundamental rights as well. The bans in force in Italy and the rules for content aimed at the Italian public also remain applicable.

In practice: the size of your community changes some obligations, not the need to make it clear straight away when content is promotional.

First check: is there a payment or a benefit?

Before choosing a label, reconstruct the real relationship with the brand. Tick “yes” if at least one of these conditions applies:

• you received a payment in money;
• the product or service was given or lent to you in exchange for visibility;
• you received hospitality, travel, a meal, entry or access to an event;
• you earn through an affiliate link, a discount code or a commission;
• there is an agreement, even an informal one, on content, timing, messages or publication;
• the benefit goes to you or to a third party in exchange for the visibility given to the brand.

The AGCOM FAQ clarify that there is no minimum fee or minimum value for a gift. A tag of the brand, a link or a discount code is not a disclosure on its own: it helps the purchase or identifies the brand, but it does not say unambiguously that the user is looking at advertising.

If you are not sure whether a benefit is linked to the content, do not settle the doubt by hiding it. Write down what you received, from whom and on what terms; then choose the clearest and most cautious wording.

Second check: which relationship does the content really describe?

Commission or promotional agreement

When content comes from a commissioning relationship, the formulas listed as immediately recognisable include “Pubblicità” (advertising), “Advertising”, “ADV” and “ADV + brand name”, as well as equivalent unambiguous formulas. According to the FAQ, “in collaborazione con” or “in partnership with” (in collaboration with) is not sufficient for a commissioning relationship: it describes a relationship, but does not clearly state the advertising nature.

Product received with no agreement to publish

For a product sent without a commission, the FAQ indicate formulas such as “gifted by” or “prodotto inviato da” (product sent by), accompanied by the name of the sender. There is one very narrow exception: when the product is not the focus, is not recognisable, there is no current or previous collaboration on the product and the brand is not granted reuse of the content. If even one of these elements is missing, the prudent choice is to make the origin of the product visible.

Invitation, event or hospitality

If there is a contract or a promotional relationship, even if the event is not expressly mentioned in the contract, the FAQ point to “Pubblicità/ADV” with the brand indicated. If instead you only receive an invitation or a service with no promotional contract, the suggested formula is “invitato da” or “invited by”, naming whoever offered the experience.

Content published days later does not automatically become neutral. If a recap, interview or follow-up still makes the brand, the event, the venue provided, the logos or a call to action recognisable, the disclosure remains relevant.

Affiliate links and discount codes

An affiliation or a code that generates an economic benefit is among the explicit signs of promotional content. Do not just show the code: flag the commercial nature with a clear formula, visible before the user has to click or expand the text.

Third check: is the disclosure in the right place?

A correct but hidden label does not finish the job. The practical rule is that people must recognise the advertising straight away, without opening the caption, listening to the end or interpreting a list of hashtags.

Posts and carousels

Put the label at the start of the caption and in any case before “altro/more”. If you use hashtags, the disclosure must appear among the first elements; AGCOM indicates within the first three hashtags. Avoid burying it at the end of a string of tags.

Reels, TikTok and YouTube videos

Put the label both as an on-screen overlay in the first scenes and in the description or caption. It must have enough size, contrast and duration to be read on a real screen. An appearance of a few frames, covered by the interface or mistaken for graphics does not help the user.

Stories

Every promotional story or clip must have a legible on-screen disclosure. It is not enough to include it on the first screen if the following ones can be viewed or shared separately.

Live

Keep the promotional nature visible in an overlay and repeat the disclosure during the live stream, especially when you present a call to action, a product or a code.

Reposts and reused content

If you republish content linked to a client, keep an adequate disclosure and name the brand. Sharing on another platform does not turn the campaign into organic content.

The platform’s “paid partnership” tool is not enough on its own

The native tools of Instagram, TikTok, YouTube or other platforms are useful and may be required by their own policies. The AGCOM FAQ specify, however, that they do not replace an immediately visible written disclosure. The most robust check is therefore a double one: switch on the tool provided by the platform and put the label in the content or in the caption, depending on the format.

This also applies when the platform’s label looks small, may change position or is not available for that specific account. Operational responsibility should not depend on a single element of the interface.

Before publishing your next piece of content answer three questions in the Ad disclosure check: we tell you which label to use and where to put it, with the checklist to tick off.

The checklist to complete before publishing

Before delivering or scheduling the content, check these points:

1. Relationship: have we written down whether it is a payment, gifting, an invitation, hospitality, an affiliation or another benefit?
2. Wording: does the chosen label really describe that relationship, without euphemisms?
3. Brand: is it clear which party commissioned or provided the benefit?
4. Format: do the caption, overlay, stories and live stream each follow their own placement?
5. Legibility: do text, contrast, duration and position also work on mobile?
6. Platform: is the required native tool switched on, without using it as a substitute for the label?
7. Brief: are deliverables, dates, claims, revisions and calls to action documented?
8. Rights: are reuse, advertising, duration and territories kept separate from simple publication?
9. Archive: are we keeping the approved brief, the final version, the caption, the agreement and proof of publication?
10. Update: have we rechecked the AGCOM and IAP sources on the release date?

To define licence, paid usage and exclusivity or to prepare the quote, go to the [creator guides hub](/it/guides) and read the deep dives on usage rights and rate cards. The specific links will be activated in editorial review only when the relevant guides are public.

From media kit to published content: a professional workflow

Transparency should not be a fix added five minutes before publishing. It starts with the way the creator presents themselves to the brand. A clear media kit makes audience, formats, examples and way of working easy to read; the brief adds goals and constraints; the proposal defines deliverables and rights; the pre-publish checklist links everything to the version that is actually published.

For a creator who works with a manager, keeping a dedicated media kit prevents data, formats and previous cases from being scattered across screenshots, messages and outdated PDFs. This presentation does not replace a contract or a legal check. Every figure must have a reference period and every case study must respect permissions, confidentiality and results that can really be documented.

An orderly flow can be read like this:

• before the brief: updated media kit, available formats and a clear commercial contact;
• before production: agreement on deliverables, total fee, rights, revisions, claims and disclosure;
• before publishing: check of label, position, legibility, native tool and approvals;
• after publishing: archive of the content, the evidence and the conditions for reuse.

Influeppy supports creators in assessing and operationally managing partnerships. It does not promise that every campaign is suitable, does not replace the opinion of a professional and does not guarantee the compliance of a specific case. The aim is to make it harder to lose an important piece of information between the brand’s first contact and publication.

The final decision in thirty seconds

If you have received money or a benefit linked to visibility, stop and identify the relationship. If it is a commission, use an explicit advertising disclosure; if it is gifting or hospitality with no contract, clearly describe the origin of the benefit with the relevant formula. Put it right where the format is consumed, use the platform’s tool as well and keep the evidence.

Being under 500,000 followers does not make these rules unnecessary. For a growing creator, a transparent process is also a professional signal: it lets the audience understand, lets the brand approve with less ambiguity and lets the team reconstruct why the content was published that way.