Rules and ethics
Part of PR agencies rules and ethics: a UK legal and ethical guide
PR agencies disclosure policy: a single record for funding, roles and AI use
How an England PR team can route funding, agency roles, supplied material, AI use, corrections and withdrawal through a factual disclosure record.
A PR agencies disclosure policy should give each item one record that covers funding, roles, control and AI use. That record states what the audience needs to know and places the information where it can affect interpretation.
There is no universal UK phrase that clears press material, sponsorship, influencer content, lobbying and AI assistance at once. The policy below is an editorial control for an England operation, not a statement that every field is legally required.
What to take away
- A disclosure record should capture relationship, control and method for each item, not rely on one standard sentence.
- Decide whether material is editorial or commercial, as paid or controlled content may fall within the CAP Code.
- Place necessary disclosures with the content they qualify, not only on a distant corporate page.
- Treat AI assistance as a factual decision, recording tool, input, review and evidence.
- If funding, control, rights or source evidence cannot be verified, withhold the item.
Create a disclosure record for each item
Give the record an owner, version and release channel. Capture the buyer and contracting legal entity, agency role, audience, funding, gifts or incentives, supplied text or images, placement control, named spokesperson, material conflicts, AI assistance, claim evidence and correction route.
Use this model record for each item and replace the entries with item-specific facts.
Create a disclosure record
- Record owner and version
- client lead, v2.
- Release channel
- national newspaper feature and Instagram Reel.
- Buyer and contracting entity
- client company and agency contract.
- Agency role
- drafting and distribution only.
- Audience
- UK general public.
- Funding or incentives
- paid brief, no gifts.
- Supplied text or images
- client-supplied product images.
- Placement control
- agency cannot approve final edit.
- Named spokesperson
- client marketing director.
- Material conflicts
- none declared.
- AI assistance
- drafting tool used, human edited.
- Claim evidence
- lab report held on file.
- Correction route
- agency account director and client legal.
- Public statement
- 'Paid partnership with client. Agency drafted and placed; publication controlled final edit. AI assisted; human reviewed.'
Do not confuse those roles. A journalist decides independent editorial treatment. An agency may draft or distribute material without being authorised to confirm every client fact. A content creator can control their account while working within a paid brief. The record should state what happened, not upgrade one party's involvement into another's endorsement.
Decide whether the material is editorial or commercial
CAP's scope guidance says press releases and editorial content usually fall outside the CAP Code, but paid or controlled material can be within remit. If the Code applies, section 2 of the CAP Code, at rules 2.1 and 2.4, requires recognisable marketing communications and clear advertorial treatment.
For incentivised online endorsements, the CMA's updated brand guidance tells brands and intermediaries to address labelling and correction. Its examples do not amount to approval of an unidentified post. A named UK advertising and consumer lawyer should decide the live application.
Place the information at the point of interpretation
Record where a reader first sees the claim, who supplied the material and whether the commercial relationship is otherwise apparent. Put a necessary disclosure with the content it qualifies. A distant corporate page should not be the only explanation where the audience needs information before interpreting a post, feature or event.
For consultant lobbying, use the separate statutory test. The Registrar's official site concerns qualifying communications with ministers and Permanent Secretaries on behalf of clients. Do not infer that every public-affairs activity belongs on that register, or that a general agency disclosure replaces required registration.
Treat AI assistance as a factual decision
The ASA and CAP's May 2025 AI disclosure article states no blanket UK legal requirement to disclose AI in advertising; existing Code rules still apply.
The policy should record the tool, input authority, source material, human review and alterations. Keep retained evidence. Then assess if non-disclosure creates a misleading impression, if client or platform terms require a statement, and if sector rules add another duty.
An AI label cannot cure an invented quotation, unlicensed asset or unsupported representation of a person. IPO's March 2026 report on copyright and AI records the policy and legal issues, but it is not permission for a specific input or output.
Correct or withdraw with an audit trail
Name the person who can pause distribution, contact a publisher or creator, correct the client record and notify affected channels.
A missing disclosure can mislead the audience, trigger a regulator complaint, and force a costly correction or takedown after publication.
Preserve the original version, reason, approval and time of action where lawful. If funding, control, rights or source evidence cannot be verified, withhold the item rather than invent a reassuring label. Recheck regulator status and sector rules immediately before publication.
Before you act
- Create a disclosure record with owner, version and release channel.
- State the agency role and what happened, not an upgraded endorsement.
- Check whether the CAP Code applies and label advertorials clearly.
- Put necessary disclosures where the audience first interprets the claim.
- Record AI tool, input authority, human review and retained evidence.
- Name who can pause, correct and notify affected channels.
Common questions
What should a disclosure record include?
Use the model record above. Keep one version per item and attach the supporting evidence.
When does the CAP Code apply to PR material?
Apply the editorial or commercial test above. The same scope guidance and section 2 rules decide it.
How should AI assistance be handled in a disclosure policy?
Use the same record as other items. The AI section above sets the evidence test.
