Before you publish a connected TV advertising disclosure policy

What to take away

The mistake most teams make is writing a disclosure policy that covers on-screen labels only, then ignoring the data and consent rules behind the same campaign. A workable policy joins both.
Connected TV ads are non-broadcast advertising, so the CAP Code applies, including the rule that ads must be obviously identifiable as ads.
Personal data used for targeting or measurement sits under the UK GDPR, which expects a lawful basis and clear information for viewers.
Budget for the admin. In the worked example below, consent notices and record-keeping add about 13 per cent to campaign cost.
Individual cases need a qualified adviser, especially on consent, children's data or financial promotions.

Step 1: Decide what the policy has to cover

Map the disclosure points in a campaign

Start by listing every place a viewer or regulator could ask whether this is an ad and who is behind it. On a connected TV screen that means the pre-roll ident, any interactive overlay, the landing page a QR code opens, and the measurement pixels fired after the impression. A policy that names only the first will fail the rest.

Disclosure points to map

Pre-roll ident
Interactive overlay
QR code landing page
Measurement pixels after impression

Write that list before drafting the wording. It doubles as your checklist and as the evidence a compliance reviewer will ask for. Our connected TV advertising: UK rules and compliance guide sets out the wider framework if you need the surrounding picture first.

Confirm which rulebook applies in England

The CAP Code governs non-broadcast ads, which covers video-on-demand and connected TV inventory served outside traditional broadcast licences. The advertising codes published by CAP and the ASA set the identification requirements you are drafting against. Where a campaign targets viewers in Scotland, Wales or Northern Ireland, the same code applies, but check platform terms that vary by nation.

Step 2: Write the disclosure and consent wording

Draft the ad identification line

Keep it short and put it where the viewer sees it before the pitch. "Advertisement" or "Ad" plus the brand name is usually enough. If the ad is personalised, say so in plain words rather than in a privacy notice nobody opens. Avoid stacking qualifiers; one clear statement beats three hedged ones.

Set out the data and consent position

If you target or measure using personal data, you need a lawful basis. Consent is one route and legitimate interests another, but the choice changes what you must tell people.

The UK GDPR as retained in UK law governs this, and the ICO's step-by-step guide to direct marketing for small businesses explains how to record that decision. Put the outcome in the policy as a sentence, not a paragraph.

Step 3: Run the policy through a worked example

Test it against a real budget

A retailer spends £12,000 on a connected TV campaign over four weeks. Of that, £9,000 buys media and £1,400 pays for creative and production.

The remaining £1,600 covers consent notice drafting, a pixel audit and six hours a month of record-keeping. That is about 13 per cent of the total, the line most teams forget when they approve the budget.

If the same campaign ran in England only, the rule position is unchanged, but platform terms and audience definitions may differ. Our connected TV advertising UK regulations in England page covers those points before you sign platform terms.

Decide what to review and when

Set a review trigger rather than a calendar date alone. New creative, a new measurement vendor or a change of lawful basis should each force a re-read. Keep a dated record of who approved each version. Regulators ask for the trail, not the intention.

Common questions

Does a connected TV ad need a visible label?

Yes, in practice. The CAP Code requires ads to be obviously identifiable, and an on-screen ident is the simplest way to meet that on a television interface.

Is consent always needed for connected TV targeting?

No. Consent is one lawful basis among several, but you must choose one, document it and tell viewers what you do with their data.

How often should the policy be updated?

Whenever creative, vendors or data practices change, and at least once a year even if nothing obvious has moved.

Can this guide replace legal advice?

No. It is general guidance only, and individual cases need a qualified adviser, especially on consent, children's data or regulated promotions.