Checking the advertising claims in a creator media kit before it goes out

What to take away

Decide the advertising route first. Promotions aimed at businesses fall under the Business Protection from Misleading Marketing Regulations 2008 (SI 2008/1276). Consumer-facing promotions sit under the CAP Code and the Consumer Protection from Unfair Trading Regulations 2008.
Attach a source, a measurement period and a definition to every objective claim in the pack. Followers are not reach.
Put limitations beside the statement they qualify. A separate evidence folder cannot repair an overstated headline.
Open the exported PDF, image deck or hosted page at normal reading size before it leaves.
Mark unresolved items individually. This checklist describes a review process and cannot certify compliance.

Which advertising route applies

The route follows the recipient, not the file format. A rate card sent to brand marketing teams is business-to-business advertising. A pack aimed at individual consumers is not. GOV.UK's summary of advertising regulations sets out that division.

Work through four questions before you touch a claim.

Identify the promoted service and each recipient group. Record business and consumer audiences separately, because one pack can carry both.
Note the statutory basis. Business-to-business promotion is covered by the Business Protection from Misleading Marketing Regulations 2008.
Decide whether the CAP Code applies. ASA remit advice separates private correspondence from standard promotional material sent to several recipients.
Keep the original sample beside the proposed presentation. A crop or extract can change what a buyer sees.

If the pack is delivered through a controlled channel rather than an open download, that changes what a reader meets first. The channel strategy comparison works through that trade-off for a UK creator.

Substantiate every objective claim

CAP Code section 3 covers misleading advertising. The substantiation rule at 3.7 requires documentary evidence for objective claims before distribution.

Five checks cover most of it:

The source is named, with the platform and the report it came from.
The measurement period is printed beside the number.
The definition is statedunique viewers, followers, impressions or sessions.
Any comparison is named and evidenced, or removed.
Contribution boundaries are described for collaborative work.

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Substantiation checks for objective claims

Attach underlying record to each factual claim
Note platform, period and definition for audience figures
Describe the work actually performed
Place limitations beside the affected statement
Define comparison and evidence for superiority claims

Do not convert followers into reach. Do not merge measures with different denominators. A separate evidence folder cannot repair a headline that overstates the underlying record.

These are editorial safeguards for a media-kit workflow. They are not a regulator's prescribed spreadsheet, and they do not prove a claim will survive a complaint.

Example: correcting an overstated reach line

The figures below are illustrative and are not drawn from any real account.

Correcting an overstated reach line

Problem

"Reach: 240,000 across Instagram and TikTok": Follower counts presented as reach, with no date or definition

Corrected wording

"Reach: 240,000 across Instagram and TikTok": Instagram followers: 96,000 and TikTok followers: 144,000, both counted on 31 March 2026. Combined follower count on two platforms. Reach was not measured.

The corrected line keeps the number, states what was counted and refuses the word reach. Comparisons need the same discipline. A benchmark borrowed from another creator without matching the population and the metric can mislead, and the benchmark research guide explains how to compare both before reuse.

Keep sponsored content recognisable

CAP Code section 2, including rule 2.1, requires marketing communications in its remit to be obviously identifiable, with their commercial intent clear.

A portfolio biography alone may not carry that. Check whether the reproduced sample still shows its advertising label. If a crop removes it, revise the presentation or leave the item out.

Do not imply the creator bought or independently chose a product when the record shows a commercial arrangement. Keep the original posting date visible, so a historical example does not suggest a current partnership.

Inspect the exported file

Open the proposed file at ordinary reading size. Check caption order, visible qualifications and legibility of source notes. If the portfolio tool refreshes audience figures automatically, record which fields can change after approval.

Consider a dated snapshot for a particular pitch. That is a version-control choice, not a legal retention period.

The file inspection checklist covers what to look at once the design is fixed, including the parts a thumbnail hides.

Common questions

Does the CAP Code apply to a media kit?

Only where the pack is a marketing communication within the Code's remit. ASA remit advice separates private correspondence from standard promotional material sent to several recipients. A pack sent to one brand after a conversation sits differently from an open download.

How do I substantiate an audience figure?

Name the platform and the source report, print the measurement period and state the definition. Followers, impressions and unique viewers are different measures. Keep the record with the file, so it can be produced if the claim is questioned.

What if I cannot verify a claim?

Remove it and note why, or return the item to whoever supplied it. Do not send a pack carrying a statement you cannot support. Mark each unresolved item on its own rather than approving the whole kit.

Can I rely on this checklist?

No. It describes a review process and cannot certify compliance. The substantive tests sit in the CAP Code and the Business Protection from Misleading Marketing Regulations 2008. Take named advertising-law advice for your own case.