Creator partnerships

AGCOM influencer advertising rules 2026: an ADV checklist for Italy

A practical checklist for creators on Italian ADV labels, gifting, invitations, affiliate links, captions, video and brand-deal records.

A reel can feel spontaneous and still be advertising. A large cash payment is not required: a gifted product, hotel stay, invitation, service, affiliate link or discount code may also matter. The useful question before publishing is therefore not “how much did I earn?”, but “is there a benefit connected to the visibility I am giving?”.

This guide explains Italian AGCOM and IAP requirements and guidance for content aimed at users in Italy. It does not claim that Italian rules apply in other countries and is not a substitute for advice on the law of your country or on a specific campaign. It translates the AGCOM operational FAQ, published on 16 March 2026, into a practical checklist for creators with communities between 10,000 and 500,000 followers. Rules can change: check the current official sources and seek qualified advice when a campaign raises legal or regulatory questions.

The 500,000-follower threshold is not a free pass

AGCOM defines a “relevant influencer” as someone who reaches at least 500,000 followers or one million average monthly views on at least one platform. Views are averaged over the previous six months; follower count is measured thirty days before the relevant notification. Reaching the threshold on one platform extends the framework for relevant influencers to the other accounts they use.

These thresholds help determine who must join the AGCOM list and comply with the specific obligations in the Guidelines and Code of Conduct. They do not mean that advertising can be hidden below 500,000 followers. The FAQ expressly invites creators below the threshold to respect advertising transparency, fair commercial communication, protection of minors and fundamental rights. Italian prohibitions and rules concerning content directed at users in Italy may still apply.

In practical terms, audience size changes certain administrative obligations, not the need to let people immediately understand when content is promotional.

First check: is there a payment or benefit?

Before choosing a label, reconstruct the real relationship with the brand. Mark “yes” if at least one of these conditions applies:

• you received money;
• a product or service was gifted or loaned in return for visibility;
• you received accommodation, travel, a meal, admission or access to an event;
• you earn through an affiliate link, discount code or commission;
• there is an agreement, even an informal one, about content, timing, messages or publication;
• you or a third party receive a benefit in exchange for visibility given to a brand, product or service.

The AGCOM FAQ says there is no minimum payment or gift value before disclosure becomes relevant. A brand tag, link or discount code is not by itself a disclosure. Those elements may identify the brand or help someone buy, but they do not clearly tell the viewer that they are seeing advertising.

If you are unsure whether a benefit is connected to the content, do not solve the uncertainty by hiding it. Record what you received, from whom and under which conditions, then choose the clearest and most cautious accurate wording.

Second check: which relationship does the content actually describe?

Commissioned or contracted promotional content

Where the content is commissioned, the wording identified as immediately recognisable includes “Pubblicità”, “Advertising”, “ADV” and “ADV + brand name”, together with equivalent unambiguous wording. According to the FAQ, “in collaborazione con” or “in partnership with” is not sufficient for a commissioning relationship. It describes a relationship but does not clearly state that the content is advertising.

A product received without a publication agreement

For a product sent without a commissioning arrangement, the FAQ identifies wording such as “gifted by” or “prodotto inviato da”, accompanied by the sender’s name. There is a narrow exception when the product is not the focus, is not recognisable, there is no current or previous collaboration concerning it, and the brand is not allowed to reuse or share the content. If all the relevant conditions are not satisfied, the cautious choice is to make the product’s origin visible.

Invitation, event or hospitality

If there is a contract or promotional relationship, including an ongoing one even when the event is not expressly listed in the contract, the FAQ points to “Pubblicità/ADV” and identification of the brand. If you only receive an invitation or service without a promotional contract, the indicated wording is “invited by” or “invitato da”, naming the party that provided the experience.

Content does not automatically become neutral because it is published several days later. If a recap, interview or follow-up still makes the brand, event, supplied location, logos or a call to action recognisable, disclosure remains relevant.

Affiliate links and discount codes

An affiliate relationship or a code that produces an economic benefit is an explicit indicator of promotional content. Do not show only the code: identify the commercial nature with clear wording that is visible before the user needs to click or expand text.

Third check: is the disclosure in the right place?

Correct wording that is hidden does not complete the job. The practical rule is that a person should recognise the advertising immediately, without opening the caption, listening to the end or interpreting a long hashtag list.

Posts and carousels

Place the disclosure at the beginning of the caption and before the “more” control. If you use hashtags, AGCOM indicates that the disclosure should appear within the first three. Do not bury it at the end of a tag sequence.

Reels, TikTok and YouTube video

Show the disclosure both as an overlay in the opening scenes and in the description or caption. It needs sufficient size, contrast and duration to be readable on a real phone. A label shown for only a few frames, hidden by the interface or confused with other graphics does not help the viewer.

Stories

Every promotional story or clip should carry a readable on-screen disclosure. A label on the first frame is not enough when later frames can be viewed or shared separately.

Live content

Keep the promotional nature visible in an overlay and repeat the disclosure during the live session, especially when presenting a call to action, product or code.

Reposts and reused content

If you repost content connected to a commissioning brand, retain an appropriate disclosure and identify the brand. Moving the content to another platform does not turn a campaign into organic content.

A platform’s “paid partnership” tool is not enough on its own

Native tools on Instagram, TikTok, YouTube and other platforms are useful and may be required by platform policy. The AGCOM FAQ nevertheless says that they do not replace immediately visible textual disclosure. The more robust check is therefore two-part: enable the platform tool and add the wording to the content or caption in the position required for that format.

This remains relevant when the platform label is small, changes position or is unavailable for a particular account. The operational decision should not depend on a single interface element.

The checklist to complete before publishing

Before delivering or scheduling the content, confirm each point:

1. Relationship: have we recorded whether this is cash compensation, gifting, an invitation, hospitality, affiliation or another benefit?
2. Wording: does the selected label accurately describe that relationship without euphemisms?
3. Brand: is it clear who commissioned the work or supplied the benefit?
4. Format: do the caption, overlay, stories and live treatment each follow the right placement?
5. Readability: do text, contrast, duration and position work on mobile?
6. Platform: is the required native tool enabled without treating it as a replacement for wording?
7. Brief: are deliverables, dates, claims, revisions and calls to action documented?
8. Rights: are reuse, advertising, duration and territories separate from the organic publication?
9. Record: are the approved brief, final version, caption, agreement and proof of publication retained?
10. Update: were the AGCOM and IAP sources checked again for the planned publication date?

For licensing, paid usage, exclusivity and quotation preparation, use the creator guides hub. Direct links to related drafts should be added in editorial review only after those guides are public.

From media kit to published content: a professional workflow

Transparency should not be a correction added five minutes before publishing. It begins with how the creator presents themselves to the brand. A clear media kit makes the audience, formats, examples and working method understandable; the brief adds objectives and constraints; the proposal defines deliverables and rights; and the pre-publish checklist connects everything to the version that actually goes live.

For a creator working with a manager, maintaining a dedicated media kit prevents data, formats and previous cases from being scattered across screenshots, messages and outdated PDFs. This presentation is not a contract or legal review. Each metric should state its reference period, and each case study should respect permissions, confidentiality and genuinely documented results.

An organised workflow can be read in four stages:

• before the brief: current media kit, available formats and a clear commercial contact;
• before production: agreement on deliverables, total compensation, rights, revisions, claims and disclosure;
• before publication: check wording, placement, readability, native platform tools and approvals;
• after publication: retain the content, evidence and reuse conditions.

Influeppy supports creators in evaluating and operationally managing partnerships. It does not promise that every campaign is suitable, replace qualified professional advice or guarantee compliance in a specific case. The objective is to make it harder for an important detail to disappear between the brand’s first message and publication.

The thirty-second decision

If you received money or a benefit connected to visibility, stop and identify the relationship. If it is commissioned work, use explicit advertising disclosure. If it is gifting or hospitality without a contract, clearly describe the origin of the benefit with the relevant wording. Put it where the format is immediately consumed, also use the platform tool, and keep the evidence.

Being below 500,000 followers does not make transparency irrelevant. For a growing creator, a clear process is also a professional signal: it helps the audience understand, helps the brand approve with less ambiguity and helps the team reconstruct why the content was published in that form.