Rules and ethics
Part of UK media buying agencies rules and ethics explained
Questions for a UK media-buying agency on ad checks
Media buying agencies UK regulations: questions to ask about UK codes, data requirements and platform policies when an agency checks a campaign.
When reviewing a UK campaign with a shortlisted media buying agency, ask how it separates applicable UK advertising and data requirements from platform policies. This guide gives you questions to use when reviewing the agency’s campaign checks; it does not rank or assess named firms. Platform acceptance does not establish that UK requirements have been met. The checks below show what each decision can—and cannot—tell you about a campaign.
Start with the point the platform check addresses
A platform policy answers whether an ad, its audience settings or its destination meets that platform’s terms. A UK code or law answers a different question. Treating one approval as a substitute for the other can leave an important issue unexamined.
Begin by locating the issue that needs checking. Is it a claim in non-broadcast copy, a broadcast ad, a promotion, an environmental claim, audience targeting, or the landing page? When briefing an agency, use that classification to ask which rulebook and platform policy the proposed execution has been checked against. This is not a substitute for reading the controlling rules; it helps you find the relevant rulebook and platform policy rather than relying on a general statement that a campaign is compliant.
Classify the communication
- Name advertiser, product, audience
- State media format and destination
- List targeting data and measurement tech
- List countries where it will run
- Flag regulated sector or age restriction
- Flag promotions, environmental or price claims
Use this checklist with the agency before approving a media buy:
- Advertiser and offer:What advertiser, service or offer is involved, and does a regulated sector or age restriction make specialist review relevant?
- Audience and data:Who is being targeted, what data informs that targeting, and do cookies or similar technologies need a UK-side check?
- Format and placement:Is the ad non-broadcast or broadcast, and which platform policy applies to the format and placement?
- Claims and promotions:Which claims need substantiation, and do the relevant provisions for promotions or environmental claims apply?
- Evidence and outcome:Which UK code or law and named platform policy did the agency check? Ask it to record the relevant account setting, the outcome of each check and any unresolved issue. Platform acceptance is not proof of UK compliance.
If the uncertainty is which UK advertising code applies, see the England advertising-rules guide. If a regulated sector or age restriction makes the case less straightforward, the England risk-scenarios guide may help identify where specialist review is needed.
Compare the UK requirement with the named platform policy
The table pairs rulebooks to help separate the checks; it does not mean that a platform policy is equivalent to a UK code or law, or that every policy applies to every campaign.
Codes, law and platform terms
CAP / BCAP codes
- Applies to
- Non-broadcast ads
- Key trigger
- Ad content and placement
- What to record
- Code and category rule
- Escalate when
- Broadcast status unclear
UK data law and PECR
- Applies to
- Direct marketing
- Key trigger
- Channel and recipient
- What to record
- Route and surrounding facts
- Escalate when
- Facts unresolved
Platform policies
- Applies to
- Account buying
- Key trigger
- Format and territory
- What to record
- Policy version and setting
- Escalate when
- UK interpretation unresolved
| UK rule or code | UK-side question | Named platform policy and platform-side question |
|---|---|---|
| CAP Non-broadcast Code: rules 3.1 and 3.7; Sections 8 and 11 where relevant | For non-broadcast advertising, check whether claims are misleading or substantiated; check the relevant promotion or environmental-claim provisions. | Google Ads Misrepresentation policy: check the ad against Google’s requirements. Google may disapprove ads or suspend accounts for policy violations. |
| BCAP Code: Section 3 | For broadcast advertising, check misleading claims against the broadcast code. Classify the service and placement; buying a video placement does not automatically make it a broadcast ad. | Meta Advertising Standards, including its Personal Attributes rules: check the ad and its targeting against Meta’s standards. |
| UK GDPR, Data Protection Act 2018 and PECR | Check the applicable data-protection and electronic-marketing requirements for the activity and channel. The answer depends on the circumstances. | Google Ads Personalized advertising policy: check targeting separately against Google’s rules; platform acceptance does not establish that UK requirements are met. |
| CAP Code: Section 8 for promotions and Section 11 for environmental claims, where relevant | Check the provision that applies to the particular claim or promotion. | TikTok Ads Policies for Ad Creatives and Landing Pages: check both the creative and destination against TikTok’s requirements. Ads may be rejected under its policies. |
For direct marketing, the ICO says organisations must still comply with the Data Protection Act and UK GDPR; where online advertising uses cookies or similar technologies, cookie provisions may also apply. Consult the ICO direct marketing guidance for that privacy question. The platform-policy check remains separate: the UK legal position is not settled simply by whether an ad can run on a platform.
Check each platform policy for its own scope
Google Ads
There are two distinct policy names to keep in view. The Google Ads Misrepresentation policy is the platform-side check for whether the ad meets Google’s requirements. The Google Ads Personalized advertising policy concerns targeting and should not be treated as a replacement for checking the applicable UK data requirements.
A useful review question is which of those issues is actually in play: the ad’s content, its audience targeting, or both. Record the relevant policy and account setting being checked. A result under one Google policy does not resolve the other question, and neither result is a UK-code or data-law determination.
Meta
Meta Advertising Standards include Personal Attributes rules. The platform-side check is not confined to the wording of the ad: the ad and its targeting both need to be considered against Meta’s standards. Keep that assessment distinct from the UK-side question of what data rules apply to the audience and activity.
Do not assume that a Meta decision answers the same question as a Google decision. The named standards are platform-specific, and platform policies can cover different requirements or territories from UK rules. Check the applicable current wording rather than relying on a result from another platform.
TikTok
TikTok Ads Policies for Ad Creatives and Landing Pages name two parts of the execution for review: the creative and its destination. Check both against TikTok’s requirements. A platform-side result about those materials does not determine whether a claim meets the applicable CAP or BCAP provisions, or whether the relevant data requirements have been met.
For any platform, keep the question narrow: which named policy applies, and what aspect of the execution is being tested? Avoid turning a platform’s acceptance or rejection into a general verdict on the campaign’s UK compliance.
Read the two outcomes separately
A paired review gives you two different findings, not one combined approval. For example, if Google disapproves an ad under its Misrepresentation policy, that tells you there is a platform-policy issue to resolve; the CAP Code question remains a separate check. Conversely, Google’s acceptance does not establish that a claim is substantiated under CAP rule 3.7.
The same distinction matters for audience decisions. A platform policy check on targeting does not establish that the relevant UK data requirements have been met. For online advertising using cookies or similar technologies, consider whether the ICO guidance on cookie provisions applies as part of the UK-side review.
Similarly, a TikTok check of a landing page is not a substitute for checking the claim or promotion under the relevant UK code. Nor does a check of ad copy alone answer whether the destination meets TikTok’s requirements. Keep the platform question and the UK question distinct when deciding what needs correction or further review.
If the policies appear to point in different directions, first identify which requirement each one addresses. A platform policy can set a platform’s acceptance conditions; the applicable UK code or law remains a separate consideration. Where the UK interpretation is unclear, send that question to a qualified reviewer rather than treating a platform decision as the answer.
Make the UK check specific to the execution
For a UK campaign, do not treat the checks as England-only: identify the code or legal requirement that applies to the execution, then assess platform policy separately. The ASA administers the CAP and BCAP Codes, handles complaints and publishes rulings; the code to consult depends on whether the material is non-broadcast or broadcast advertising.
Platform policies can change, and account settings matter to the platform-side check. When briefing or reviewing a media-buying agency’s campaign recommendation, reopen the relevant policy wording and account setting rather than relying on an old policy reference or a decision from another format. Keep the result specific: name the UK code or law considered, name the platform policy checked, and state what each decision covers.
That comparison makes it easier to see what remains unresolved. A platform rejection may call for a platform-policy review; a question about a claim, promotion, audience data or contact method calls for the corresponding UK-side assessment as well. Neither label—approved nor rejected—should stand in for the other check.
