What does the ASA CAP Code require in vertical video ads?

Does a vertical frame change which ads the code reaches?

No. A commercial message aimed at UK consumers remains a non-broadcast ad when shown in portrait video. Payment, brand control, boosting, affiliate promotion or use of a company account can bring a clip within the CAP Code, regardless of the shape of the screen.

The Committee of Advertising Practice writes the code and the ASA enforces it. Paid vertical ads on TikTok, Instagram Reels, YouTube Shorts, Snapchat and Facebook fall within its non-broadcast scope, whether boosted or sold directly. Platform approval does not establish code compliance, just as code compliance does not settle platform rules.

The rules that matter most sit in a few sections of the code. Section 2 covers recognition of marketing communications. Section 3 covers misleading advertising, evidence, testimonials and comparisons. Section 4 covers harm and offence, and Section 5 covers children. The sections below name the rule behind each requirement.

Other obligations can apply alongside the CAP Code. Use broader UK ad rules to consider a campaign's wider requirements, and make sure reviewers distinguish platform acceptance from compliance with advertising rules. Vertical presentation changes how viewers encounter the message, not the basic question of whether it is an ad.

Where should a commercial relationship appear?

Disclose a commercial connection when creator content is not editorially independent. Payment is not the only trigger: a gift, loan, free stay, travel, tickets or exclusive access can also create a relationship viewers need to understand when they see the promotion.

A creator earning commission through a code or link should make that interest clear in the video or accompanying caption. Do not leave the disclosure in a bio or comment for viewers to find later. The creator disclosure checks can help teams account for affiliate arrangements as they prepare creative.

The source of this requirement is rule 2.1, which says marketing communications must be obviously identifiable as such. Rule 2.3 adds that an ad must not falsely claim or imply that the marketer is acting as a consumer, and must make its commercial intent clear if that is not apparent from the context. A creator post that hides a paid relationship can breach both.

Company channels are not exempt simply because an outside creator is absent. If the commercial purpose is not obvious, identify the post as advertising. For example, a Manchester creator given two complimentary hotel nights for a Reel should identify the gifted stay in the opening and caption, with booking commission beside its link.

How soon should viewers see the ad label?

Make the advertising nature clear from the beginning, before viewers must interpret the message or tap elsewhere. In a vertical clip, place the label at the outset and keep it readable long enough to register before someone scrolls past.

Use a direct label such as Ad or Paid partnership with the brand, and repeat the information in the caption. A spoken thank-you, quick logo flash or vague tag such as #sp may not make the commercial purpose clear. Decide on wording, position and timing while preparing the disclosure policy, rather than waiting until upload. The ASA and the CMA publish a joint influencers' guide to making clear that ads are ads, and it is a sensible reference for label wording.

Treat the video, caption and platform disclosure tool as complementary. Instagram's paid partnership label, TikTok's branded content toggle and YouTube's paid promotion checkbox can add context, but do not guarantee recognition by themselves. Review the creative with sound off and make sure a promotional claim does not appear before the label.

Which parts of a short clip count as a claim?

Review the ad as a whole, not only its script. Spoken words, captions, overlays, music and editing all shape the impression, so factual claims need support and any important qualification must be clear in the finished presentation.

A short duration does not turn a factual statement into mere opinion. Check whether the words and images are accurate, supported and unlikely to mislead, and include qualifications where viewers need them to understand the claim. A separate destination page cannot reliably correct an impression already created by the video.

Four rules do most of the work here. Rule 3.1 says an ad must not materially mislead or be likely to. Rule 3.3 covers misleading by omission. Rule 3.7 requires documentary evidence to be held before the ad runs, for any objective claim. Rule 3.9 requires significant limitations and qualifications to be stated, and a qualification may clarify a claim but not contradict it.

Testimonials and endorsements sit in the same section, from rule 3.45, which requires documentary evidence that a testimonial is genuine and contact details for whoever gave it. Comparisons with an identifiable competitor are covered by the comparison rules in the same section and must not mislead about either product.

Testimonials should be genuine and representative, and an endorsement should reflect the endorser's real opinion. If a creator talks about a supplement as a user, do not remove relevant context about varying results just to shorten the clip. Presenting scripted personal experience from someone who has not used the product is problematic.

Claims such as better than or the UK's number one need evidence and a clear comparison basis. Health, beauty, finance and food claims can require particular care, including claims about weight loss, income, credit or nutrition. Consider caption accessibility when reviewing text shown on screen.

Which other rules depend on the product or audience?

The CAP Code has separate sections for harm and offence (Section 4), children (Section 5), privacy (Section 6), promotional marketing (Section 8), distance selling (Section 9) and database practice (Section 10). Check the sections relevant to the product, audience and campaign rather than assuming every vertical ad raises the same issues.

Health-related products have their own sections. The code's food and food supplement rules expect nutrition and health claims to be authorised on the GB nutrition and health claims register. Medicines, weight-control and beauty claims each have separate sections too. A general review of a clip does not replace checking the section its content triggers.

Promotions such as prize draws and giveaways fall under Section 8, which requires significant conditions, such as closing dates and eligibility, to be stated. A creator giveaway in a Reel needs those terms in the caption at least.

Build the review around the actual creative and intended audience. Teams can use UK compliance checks alongside the code review, while keeping platform policies and other UK requirements distinct from CAP Code obligations.

What may follow an ASA complaint?

An upheld complaint can lead to an ad being changed or withdrawn, and the ASA may publish a ruling or identify an advertiser as non-compliant. Repeated breaches can bring further pressure, including paid search ads naming the advertiser or a referral to Trading Standards.

Published rulings explain what an advertiser did, what a complainant challenged and why the ASA upheld or dismissed the case. The ASA cannot fine an advertiser; its responses include publishing decisions and naming advertisers, while persistent breaches can lead to further action. These outcomes make it important to keep approval decisions connected to wider UK regulations.

Trading Standards may pursue persistent breaches under consumer protection law, including through court proceedings. That law is now the Digital Markets, Competition and Consumers Act 2024, which replaced the Consumer Protection from Unfair Trading Regulations 2008 in April 2025. The CMA can also act on misleading commercial practices, while platforms may affect account status or advertising access after repeated breaches. Keep a record of the final creative and the evidence considered during approval.

When is it useful to ask for Copy Advice?

Ask before publication if a claim, disclosure or comparison remains uncertain. ASA Copy Advice is a free, confidential opinion on whether a particular ad is likely to breach the CAP Code, but it is not binding pre-clearance and cannot guarantee the outcome of a later complaint.

Provide the finished creative or a detailed script, the channels, intended audience and evidence for claims. Submit the caption, spoken words and on-screen text together because the ASA considers the complete ad. A script that appears compliant on its own does not resolve a conflicting caption or overlay in the final version.

Advice does not prevent a later complaint from being considered on its merits. It can help reduce risk and show that advice was sought, but no outcome is guaranteed. It is most useful while the creative can still be changed, rather than after the vertical video has gone live.

For regular campaigns, combine an internal code review with Copy Advice on borderline questions. Prepare a phone-shot video or detailed script, and set expectations through supplier service standards so creators know what to provide and when approval is required.

What should I do first?

Start by checking the label, claims and creator relationship in the finished ad before publication. Keep the script, caption, evidence and approval record together, and seek Copy Advice on a borderline point while changes are still possible.