Canada's Updated Influencer Marketing Disclosure Guidelines: Navigating AI, Affiliate Marketing, Child Audiences And More

In October 2025, Ad Standards, Canada's advertising industry self-regulatory body, released an updated version of its Influencer Marketing Disclosure Guidelines (the "Guidelines"). The Guidelines incorporate new direction for brands and influencers regarding AI, affiliate marketing, child audiences and related topics.

The Guidelines are an important resource for brands and influencers to help ensure that influencer marketing campaigns comply with applicable Canadian advertising requirements. Originally published in 2018, brands, influencers and audiences should now be generally familiar with the requirement to clearly and prominently disclose #Ad, #Sponsored or similar "material connections" within influencer advertising, to comply with rules against deceptive marketing practices addressed within the Guidelines.

The latest version of the Guidelines continues to address these key disclosure principles, as well as the application of these principles to evolving areas of advertising, notably those affected by new technology and current marketing trends.

Brands and influencers should be aware of the following significant updates that are now incorporated within the Guidelines:

• Recognized hashtags and "the gold standard": The new Guidelines specify that #Ad (used on its own and not combined with other words) is the "gold standard" disclosure hashtag for influencer campaigns, as it easily understood by viewers.
  
  Use of #Gifted (where the influencer is not required to post about the brand but received a free gift) and #InvitedGuest (where the influencer was invited to attend an event but not required to post about it) have been added to the Guidelines as recognized clear and widely accepted hashtags. These additions, paired with related updates to the Guidelines, reflect that where an influencer receives payment other than financial compensation, such as a free product or an exclusive event invite, this is a form of material connection to a brand that should still be disclosed if an influencer decides to post.

• Using AI-generated influencers and content: The Guidelines have been revised to specifically address the use of AI in influencer advertising. Importantly, AI-generated influencers must follow the same material connection disclosure rules that apply to other forms of influencer advertising. In addition, best practice is to disclose that the spokesperson is virtual (for example, disclosing #VirtualInfluencer, #AIinfluencer or #AIcreated).
  
  Regarding AI-generated influencer content, if an image that shows the benefits or attributes of a product is generated by or significantly altered using AI, this should be disclosed (for example #MadeWithAI or #AIcreated). The Guidelines also remind brands and influencers that posts created using filters or AI must not result in misleading or exaggerated claims—despite filters and AI tools available, content must remain truthful as to the benefits, results and attributes of an advertised product or service.

• Extra care is needed for child audiences: When it comes to making compliant disclosure of material connections between brands and influencers, influencers with a child audience must take extra care to ensure that this audience understands the advertising nature of their message. Disclosure should be attention-grabbing, intrusive and properly explained using age-appropriate language.
• Disclosing affiliate links: The Guidelines have been revised to further clarify that where an influencer is receiving a commission, discount or free products as a result of sales generated through affiliate links, this fact must be clearly and conspicuously disclosed (for example, by using #affiliate, #AffiliateLink or #CommissionEarned). This disclosure should appear on every page and post where these links are presented.
• "Do" use platform disclosure tools/settings: The Guidelines previously encouraged material connection disclosures to be independent of, and used in addition to, platform-specific settings (such as a "paid partnership" platform tool). However, under the updated Guidelines, "where a tool provides prominent, clear and effective disclosure, additional disclosure is not required."
  
  Nevertheless, brands and influencers should remain diligent to ensure that, where relied upon, a platform's disclosure tool provides prominent, clear and effective disclosure that follows the principles set out in Guidelines. Such tools must provide disclosure regardless of the device used to view the post and how the post is viewed—when in doubt, influencers should include their own disclosure (for example, #Ad) in addition to their use of such tools.

• Consider "safe zones": Safe zones are areas within a social media post where disclosures should be placed to ensure that they remain visible and unobstructed across different devices and formats. The updated Guidelines clarify that its disclosure best practices are intended to ensure disclosures are clear, conspicuous, and broadly understood regardless of which device is used to view the post (desktop, tablet, smart phone, etc). How an influencer's posts are typically viewed by their audience, and the safe zones of each applicable platform, should be considered to ensure that disclosures are clearly visible and not missed.

The Guidelines continue to act as a helpful roadmap for brands and influencers looking to determine how, when, and what to disclose when engaging in influencer marketing. The Guidelines are intended to be a living document and periodically revised as marketing trends and technology evolve.

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