A fee for a post, a product sent without any obligation to feature it, and an invitation to a PR event represent different relationships between a brand and an influencer. Audiences should be able to understand which of these is behind the content they follow. These are precisely the distinctions addressed in the updated guidelines from the Slovenian Advertising Chamber (SOZ), Influencer Marketing – Recommendations for Implementation and Labelling, which connect responsible collaboration with clear labelling, truthful claims and the obligations of all participants.
The document is part of the Good Practice project, through which SOZ develops practical recommendations for high professional standards in marketing communications. It draws on Slovenia’s legislative and self-regulatory framework and is intended for advertisers, agencies, influencers and other participants. The recommendations apply regardless of follower count, with the authors noting that individual situations require an assessment of the specific circumstances and applicable regulations.
The basic principle is that users must recognise advertising content when they first encounter a post. The label must therefore not be hidden among hashtags, behind an option to display additional text, or somewhere it is difficult to notice. In a sequence of advertising stories, each must be labelled individually, as users may begin watching at any point. In podcasts, the advertising nature of the content must also be clearly disclosed in the audio recording; a label in the episode description alone is not sufficient.
The recommendations distinguish between types of collaboration. For posts created in exchange for money, a product or a service, as well as collaborations in which an influencer earns commission through a special link or code, the prescribed Slovenian labels are Oglas, Oglasno sporočilo or Plačana objava. A product received without an agreement or obligation to post may be labelled Darilo, while posts from events or media trips without an agreement to publish are recommended to carry labels such as PR dogodek, Medijski dogodek or Medijski izlet. Attendance at an event alone, the document explains, does not mean that every post is an advertisement.
It is also important to clearly identify the actual advertiser. The agency through which the collaboration and payment are arranged does not replace the company in whose interest the advertising is carried out.
The document addresses what influencers say or show in equal detail. Personal experience should only be presented if the product or service has actually been tried, and verifiable claims must be supported by appropriate evidence. Filters, retouching and artificial intelligence tools must not create a misleading impression of a product’s effects.
Responsibility therefore extends throughout the collaboration. Companies should establish clear rules in advance, review published content and have a procedure for correcting irregularities. The fact that content has previously been approved by the advertiser or agency does not absolve influencers of responsibility for their own posts. The document also recommends setting out collaborations in writing, particularly for longer-term, more complex or financially significant engagements, including content usage rights and the period during which a post should remain available.
A separate section is devoted to children and underage influencers, their privacy, dignity and safety. The guiding principle is that the best interests of the child take precedence over commercial interests.
The working group that prepared the document was led by Dr Branka Bizjak Zabukovec, with Anja Oman, Ajda Sitar Žumer, Živa Deu, Tara Urbančič, Gregor Memedović, Eva Remic, Vid Pavlica, Veronika Košir Firbas and Nina Jakovljević also contributing to its development. Mojca Briščik, CEO of SOZ, thanked the authors for their expertise and contribution, saying: “Together, we are taking another important step towards more responsible, transparent and trustworthy influencer marketing.”
The document concludes with checklists for advertisers and influencers, covering everything from assessing the suitability of a collaboration to reviewing a post as users see it. This translates the principle of transparency into a concrete working procedure: establish the relationship with the brand, label it clearly, and review the content before and after publication.
