Last week, the European Advertising Standards Alliance ("EASA") released its "Best Practice Recommendation on Influencer Marketing."  

EASA is not a self-regulatory organization, but supports the work of advertising self-regulatory groups and coordinates the implementation of best practices.  EASA issued this new guidance to help self-regulatory organizations create their own guidance on influencer marketing issues.  Here are some of the highlights. 

EASA recommends that influencer content should be considered "advertising" when the advertiser has editorial control over the content and if the advertiser compensated the influencer for posting the content, either by payment or through other reciprocal arrangements. 

The guidance also says that it is critical that influencer marketing be recognizable as advertising.  EASA wrote, "All influencer marketing should therefore be designed and presented in such a way that the audience immediately identifies them as such." 

EASA also emphasized the importance of disclosing the connection between the advertiser and the influencer.  EASA said that the disclosure could be made in a variety of ways, but that it was most important that the disclosure should appear "instantly."  EASA also said the placement, timing, labelling, and wording of the disclosure should be considered.  

In issuing the guidance, EASA noted that influencer marketing guidance has already been issued in Belgium, France, Germany, Ireland, Italy, Sweden, the Netherlands, and the United Kingdom.  EASA also said that guidance is under development in Austria, Romania, and Spain.