Rules and ethics
Part of Mapping UK conversion rules to each store decision with separate review gates
Ecommerce conversion disclosure policy for stores
An ecommerce conversion disclosure policy for online stores: four label classes, a relationship register, placement rules and a checklist for every claim.
An ecommerce conversion disclosure policy should tell an editor what must be made clear, where, by whom and for how long. It is not a footer that cures a misleading claim, missing permission, unsafe product or unlawful data operation. This method uses official records checked on 6 September 2026 and needs qualified review for the actual merchant and audience.
What to take away
- A disclosure policy must state what is made clear, where, by whom and for how long.
- Four classes cover editorial content, commercial content, supplier evidence and uncertainty.
- Material commercial context belongs where the audience makes the decision, not in a footer.
- Every record needs a version, owner, approval date, review date and expiry.
- Labels are approved per field and tested on the conversion path.
Create four disclosure classes
First, mark editorial content where the merchant or publisher is making an independent editorial assessment. Record the evidence and any relevant relationship even when the conclusion is not paid.
Example label: Editorial. Written by our team. No payment or commission affected this assessment. Evidence checked [date].
Second, mark commercial content. This includes sponsorship, paid placement, controlled advertorial and affiliate arrangements where payment or commission affects the content. CAP Code Section 2, and rule 2.1 within it, requires covered marketing communications to be obviously identifiable. ASA advice online guidance on affiliate marketing explains why the commercial nature of affiliate-linked content must be clear.
Example label: Ad. Paid placement by [Brand]. We may earn commission if you buy through links.
Third, mark supplier evidence. A published specification, case study or roadmap is a statement from the supplier unless independently verified. Identify the exact product, edition, territory and document date. Do not rewrite a supplier's claim as an observed merchant result.
Example label: Supplier claim. This specification comes from [Supplier] and has not been independently verified by us.
Fourth, mark uncertainty. Use it for missing evidence, unresolved applicability, estimates, untested assumptions or results that do not support causation. Uncertainty should be visible near the conclusion it limits, not hidden in an archive.
Example label: Uncertain. This estimate uses limited data and does not prove causation.
Build the relationship register
For each page, message or component, record content owner, advertiser or commercial partner, payment or benefit, editorial control, affiliate destination, evidence owner, approval date and expiry. Include gifts, free access and non-cash benefits. If the relationship changes, reopen the disclosure decision.
| Page or component | Content owner | Commercial partner | Payment or benefit | Editorial control | Affiliate destination | Evidence owner | Approval date | Expiry |
|---|---|---|---|---|---|---|---|---|
| [Example page] | [Named owner] | [Example brand] | [Affiliate commission] | [Final copy approval] | [Example URL] | [Named owner] | [YYYY-MM-DD] | [YYYY-MM-DD] |
The Digital Markets, Competition and Consumers Act 2024 is the source of the unfair commercial practices rules that apply from 6 April 2025. The CMA's unfair commercial practices guidance covers failure to identify commercial intent, misleading presentation and fake-review practices under those provisions. Apply the consumer-law review to the overall presentation, not only the chosen label.
Put the explanation where the decision happens
Map every point at which a shopper acts: the product page headline, the first price shown, a comparison table, a recommendation carousel, a review, the first affiliate link, the add-to-basket button, checkout and the order confirmation. Paid search and social landing pages, email and republished fragments need the same treatment. The audience should meet material commercial context in time to understand the message, which usually means above or beside the claim rather than in a footer. Check small screens, assistive technology, images, video and shared content. A platform label can supplement the policy, but its existence does not settle adequacy.
For example, on a product review page, keep the platform affiliate label at the top of the review and place the policy label next to the first price link and again at the add-to-basket button where the review links straight to purchase.
The Equality and Human Rights Commission's Equality Act 2010 service-provider guidance, including its disability quick start guide for service providers, provides the Great Britain context for anticipating access barriers. Give disclosure text a meaningful reading order, clear language and an equivalent non-visual route. Accessibility review remains separate from advertising approval.
Measure the effect on conversion
Every label sits on the path the shopper takes to order, so its placement is a conversion decision rather than a house style. Build two variants of the same page: the platform label alone, and the platform label plus the policy label beside the first price link, add-to-basket button, recommendation or payment step. Show each to a comparable share of traffic and read the outcome on add-to-basket rate, checkout completion and conversion rate, alongside returns, refunds and complaints.
Short-term click loss is not a reason to soften a label the law requires. Where the wording is optional context, test whether it earns its space; where it is required, fix wording and placement until it reads clearly and the funnel recovers. Keep the losing variant on record so the decision can be re-run when the page, offer or channel changes.
Keep evidence and permission apart
Attach the exact claim, supporting record, date, conditions and withdrawal trigger. CAP Code Section 3 sets the substantiation and misleading-advertising rules, with rule 3.1 requiring that a marketing communication must not materially mislead. Labelling an item as an advertisement does not substantiate it.
A privacy notice is another kind of information. The Privacy and Electronic Communications Regulations 2003 govern the storing of information on, and the gaining of access to information stored in, a user's device: regulation 6 requires consent for cookies and similar technologies, and the ICO's guidance on cookies and similar technologies sets out how to comply. An advertising disclosure does not create PECR consent, determine a UK GDPR lawful basis or authorise direct marketing.
Product-safety communication also remains distinct. Current OPSS guidance describes traceability and corrective action. A commercial label cannot validate a safety claim or replace a warning, recall or withdrawal decision.
Adopt these policy clauses
- Scope.This policy covers every page, message and component that carries a claim, price, comparison, recommendation, review or link, on every channel the store publishes.
- Labels.Every item is marked editorial, commercial, supplier evidence or uncertain, using the wording set out in the four classes above.
- Placement.The label appears in the same view as the item it qualifies and before the decision it affects.
- Register.Every item has a relationship register entry listing content owner, commercial partner, payment or benefit, editorial control, affiliate destination, evidence owner, approval date and expiry.
- Evidence and permission.Supporting records are attached to the exact claim, privacy notices and safety warnings stay separate, and no label is treated as consent or as substantiation.
- Version control.Every entry carries a version, an owner, an approval date and a review date; expired entries are taken down or re-approved before they are shown again.
- Sign-off.Commercial labels are approved by the advertising and affiliate compliance lead, claim wording by the consumer-law adviser, cookie and marketing statements by the data protection officer, reading order by the accessibility lead, and product warnings by the product-safety manager.
- Correction.Broken labels, changed destinations, expired evidence and withdrawn products follow the correction, customer-notification and withdrawal routes set out in this policy.
Operate the policy
Monitor live placement, broken labels, changed destinations, expired evidence and republished fragments. Preserve the previous version and the decision history. The routes below are policy choices a store can adopt as written or adjust, with its own adviser's review.
- Correction:fix a broken or missing label within one working day of detection. Remove a claim that may mislead within four working hours, and re-approve it through the same field owner before it returns.
- Customer notification:where a purchase was made within the last 30 days on a materially wrong claim or missing commercial label, email the customer within five working days with the correction and the refund or cancellation route.
- Withdrawal:take an item down on its expiry date unless re-approved, and withdraw a product claim at once if safety evidence is withdrawn.
- Review dates:set the review date 12 months after approval for evergreen pages and 3 months for promotions, with expiry at the campaign end.
- Retention:keep each register entry and decision record for six years, which matches the six-year limitation period for contract claims in England, then delete it.
Sign-off is per field, not per page. The advertising and affiliate compliance lead approves commercial and sponsor labels, the consumer-law adviser approves claim wording against the unfair commercial practices rules now in force, the data protection officer approves any statement about cookies or marketing, the accessibility lead approves reading order and non-visual routes, and the product-safety manager approves warnings. Where a relationship, an evidence source or a legal scope is unresolved, the item stays unpublished until its field owner settles it.
Before you act
- Mark each item as editorial, commercial, supplier evidence or uncertain.
- Build a relationship register covering payment, control and affiliate destinations.
- Place disclosure near the first claim, price, link or payment step.
- Keep substantiation, privacy consent and safety warnings separate from labels.
- Give every record a version, owner, approval and expiry.
- Test the label's placement against add-to-basket, checkout completion and conversion rate.
- Hold the item until the field owner named in the policy signs it off.
Common questions
What should a disclosure policy actually specify?
It should tell an editor what must be made clear, where, by whom and for how long. It is not a footer that cures a misleading claim, missing permission, unsafe product or unlawful data operation, and it needs qualified review for the actual merchant and audience.
How should supplier evidence be labelled?
A published specification, case study or roadmap is a statement from the supplier unless independently verified. Identify the exact product, edition, territory and document date, and do not rewrite a supplier's claim as an observed merchant result.
Does an advertising label settle privacy or safety duties?
No. They are handled under the separate evidence and permission review above.
