What Is UGC? How Creator Promotion Is Labelled

What Does User-Generated Content Mean?

The term UGC is used for more than one thing. This post uses it for two. The first is content a user puts on a service, which is how the Online Safety Act uses the term. The second is a video made by a creator to promote a brand, which the platforms call branded content.

The Online Safety Act 2023 defines user-generated content, for a user-to-user service, as content generated directly on the service by a user of the service, or uploaded to or shared on the service by a user of the service, that may be encountered by another user, or other users, of the service by means of the service.¹

The Act says content generated, uploaded or shared by a user includes content generated, uploaded or shared by means of software or an automated tool applied by the user.¹

The section says it applies for the purposes of this Part of the Act.¹

That is a definition inside one UK Act. It tells you what counts as user-generated content there. It is not a labelling rule.

Under that wording, a video made with AI tools and then posted by a user can still be content the user generated, uploaded or shared. For a creator, the labelling question comes next: is anyone paying for the promotion, or giving something in return?

What Do Platforms Call Creator-Made Promotion?

TikTok spells out what its definition covers.

• A product or service that has been gifted to you by, or on behalf of, a brand.²
• A brand, product or service that you have been paid to post about, whether in the form of money or a gift.²
• A product or service for which you will receive a commission on any sales, for instance via an affiliate link or promotional code.²
• A brand that you have or have had a commercial relationship with, such as acting as a brand ambassador.²

YouTube separates endorsements, which carry a message that reflects the opinions, beliefs, or experiences of the creator, from sponsorships, which are videos financed in whole or in part by a company.³

In all three pages the trigger is the arrangement behind the video, such as payment, a free product or a commission.

What Does Each Platform Make A Creator Do?

Meta adds that if the post is boosted or is an unpublished ad, an Ad label appears, just like it would with any other ad.⁴

TikTok says the product or service you are promoting must be sufficiently clear without requiring viewers to access your profile page or any links, for instance by identifying it verbally or in the text caption.²

YouTube adds that you and the partners you work with are also responsible for understanding and complying with all applicable legal requirements.⁵

TikTok's Branded Content Policy page shows a publication date of 4 August 2026 and an effective date of 31 August 2026.²

Use the platform's own tool every time. These pages change, so read the current version of each before you rely on it.

What Does A UK Regulator Say About Labelling Ads?

The CMA's guidance says that if you have been incentivised in any way to promote a brand or product, the content must be clearly identifiable as an ad and reflect your genuine experience.⁶

• Any form of incentive or reward, including money, commissions, discounts and gifts of any products, is payment.⁶
• The guidance applies if you have received a product for free or at a discounted rate, or other incentives such as direct payment or commission, no matter how many followers you have.⁶
• It is not enough just to tag a brand in your post, use discount codes or affiliate links.⁶
• Labels such as ad, advert, advertising and advertisement clearly identify content as an ad.⁶
• Some platforms have tools that label content automatically, like paid partnership or branded content, and you can use them provided the label is clear and easy to see or access.⁶

If a labelling tool does not clearly convey that the content is an ad, the CMA says you should include the label #Ad in a clear, upfront position.⁶

The CMA lists #gift, #gifted, #sponsored and thank you among the unclear or ambiguous terms to avoid.⁶

It says your audience should not have to access your profile page or bio to see that content is an ad.⁶

For videos, it says the disclosure for ads must be given at the beginning of the ad.⁶

The CMA calls hidden ads illegal and harmful, and says you could face enforcement action from the CMA, local authority Trading Standards Services, or the Department for the Economy in Northern Ireland if your content misleads consumers.⁶

These pages are about the UK. If your audience or your brand partner is elsewhere, look for the equivalent page from the regulator there before you post.

Does A Video With No Creator On Camera Still Need A Label?

None of the pages used here ties the labelling rules to a person appearing on camera. They turn on the arrangement behind the content.

The CMA says its rule applies to any content, including photos, videos, reels, stories, podcasts and other posts online.⁶

It also says posting about products or brands without labelling them as an ad can mislead your audience if you give the impression that you have used the product yourself when you have not.⁶

The CMA says the content must also not make false or unsupported statements, and TikTok says you must not make false, deceptive or misleading claims about any products or services.^{6 2}

TikTok says you are responsible for ensuring that any Branded Content that you post complies with all applicable laws and regulations.²

DreamWild makes the video, and its Terms leave the label, and the claims the video makes, with the person who publishes it.

For a channel with no face on camera, the script is the thing to read closely. A first-person line that says the narrator tried, bought or used a product is a claim about experience. Keep it only if it is true for the person who posts.

If the video has a narrator or an animated character, have it say or show the ad label early, use the platform tool as well, and name the product or service in the video or the caption, not only in a link.

What Should You Check Before You Post A Promotional Short?

• Has anyone given you money, a free product, a discount code, a commission or a place on an affiliate programme for this video? If yes, treat it as an ad.
• Is the platform's own paid promotion, branded content or disclosure setting switched on before you publish?
• Does the video make clear it is an ad from the first moment, without anyone opening the profile, the bio or a link?
• Does the script claim a purchase, a personal experience or a result that did not happen? Cut it or make it true.
• Is the product or service named in the video or the caption, not only in a link?
• Is the brand in an industry the platform bars or restricts for branded content?

TikTok bars branded content for a list of industries, including weight loss products or services, and for financial services such as pyramid schemes, multi-level marketing opportunities, payday loans and get-rich-quick schemes.²

For restricted industries such as alcohol, and financial services covering loans, credit cards, insurance and investment services, TikTok says you can only post branded content if you have been invited by an approved brand.²

Keep a note of the brief, the label you used and the date, in case a platform or a brand asks.