Written evidence submitted by the

Influencer Marketing Trade Body


Submission to the Digital, Culture, Media & Sport Select Committee inquiry into INFLUENCER CULTURE



04 May 2021



  1. The influencer marketing industry is valued at $10 billion globally and is forecast to be worth $15 billion in 2022[1]. The industry is experiencing a 62.56% annual growth rate. The 2020 size of market is twenty times the size of the same market in 2015.


  1. Around 60% of internet users in the UK aged 16 to 64 follows influencers[2]. It is clear individual generations engage differently with social platforms depending on the type of content they are actively interested in.


  1. The industry has attracted many new entrants capitalising on the market’s expansion. The number of influencer marketing-focused platforms and agencies has grown from 190 in 2015 to 1,360 in 2021.[3] With relatively low barriers to entry it is inevitable that there will be a few bad actors alongside many good actors operating within the industry.


  1. The Influencer Marketing Trade Body (“IMTB”) is a newly-formed professional membership organisation dedicated to professional standards and lifelong learning. It will do so by supporting the careers of its members and building public understanding of influencer marketing to the benefit of advertisers, regulators and society at large. The IMTB was established in 2021 by six founder members: Ogilvy, INCA, Whalar, The Fifth, Tagger and Takumi. These well-established, leading organisations represent influencer agencies, influencer talent agencies, and influencer platforms.             


  1. The long-term aim of the IMTB is to ensure a robust, sustainable future for influencer marketing achieved through the promotion of industry collaboration between our members, by speaking as a unified voice and by earning a place as a trusted source of research including tracking the rise in professionalism of the industry and accurately forecasting its market size. The IMTB will also provide industry guidance & education for the market.


  1. Several industry awards competitions in the United Kingdom now include influencer marketing categories. Category winners demonstrate best practice raising the standards of future influencer marketing campaigns. Several online publications, email newsletters and podcasts are now dedicated to tracking influencer marketing news and best practice.


  1. While there exist a few bad actors, the professionalisation of the industry will help to raise standards across the board led by the IMTB. Just as in other forms of marketing, there will always be outliers, the advertising regulator is equipped to deal with those.


  1. In the United Kingdom influencer marketing is regulated by the Competition and Markets Authority (CMA), the Advertising Standards Authority (ASA) alongside the Committees of Advertising Practice, the Financial Conduct Authority and the Medicines and Healthcare products Regulatory Agency.


  1. It is in the influencer marketing industry’s best interests to uphold high standards and promote compliance with advertising rules. Trust is central to the relationship which influencers have with their audiences, thus failure to comply with regulation risks undermining the confidence which audiences have in the authenticity of an influencer’s promotions. At an industry level, diminishing the impact of this nascent discipline by bringing it into disrepute risks advertisers’ willingness to work with reputable players in the market.


  1. There is mounting scrutiny of influencer marketing with regards to advertising and consumer law. Consideration should also be made in the context of the protection of children and the vulnerable via media literacy programmes against negative role models on social media.


Influencer Marketing Trade body responses to the questions

Defining social media influencers

Question: How would you define 'influencers' and ‘influencer culture'? Is this a new phenomenon?


  1. Social Media Influencers (‘influencers’) are opinion leaders. They are a modern incarnation of those defined in 1955 by Katz and Lazerfield as ‘individuals likely to influence other people in their immediate environment’[4]. Influencers are therefore not a new phenomenon. The proliferation of social media platforms such as Facebook, Instagram, TikTok, Twitter and YouTube, however, created the pipes from which influencer content could flow and their communities built.


  1. Influencers do not belong to a single homogenous group. They represent different sections of society. They operate within one or more social media platforms. They exist within different subcultures. They behave in markedly different ways to each other depending upon the social media platforms they publish to, the subcultures they are part of, and their motivations to influence their community.


  1. The origin of an influencer’s source of influence is relevant. There is a distinction between celebrities such as actors, singers, sports personalities, fashion models and reality TV stars made famous outside social media but who use social media for their personal and professional promotion and influencers who were 'born on social media' and who are exclusively known for their activity on social media[5]. The latter has often spent years honing an online presence, developing subject matter expertise and nurturing an online community. The former - especially reality TV stars - have often had large social media followings thrust upon them.


  1. Academic and industry writing tends to confine definitions of influencers to the facet of third-party endorsement. This is reductive. Influencers may collaborate with firms to advertise products or services. The essence of an influencer is not their ability to sell, however. It is their ability to inspire a community toward action through publishing consistent, relatable, regular, and authoritative content.


  1. The outcome of influencer content can be the realisation of a financial opportunity through a brand collaboration. However, the influence of an influencer may be applied to affect many differing outcomes. For instance, influencers often coalesce around macro issues that stand to impact their generation and society as a whole. Influencers increasingly document issues they care about to bring heightened awareness and ultimately to affect positive change. It should be noted there exists a small minority of influencers who represent negative role models and from which children should be protected.



Influences and popular culture

Question: Has 'influencing' impacted popular culture? If so, how has society and/or culture changed because of this side of social media?


  1. People often see influencers as compelling communicators, rivalling household names, journalists and media mastheads. Online audiences increasingly favour influencers who take a stance on societal and political issues and who use their platforms to discuss current affairs. Many influencers are adept at carrying important messages to principally younger audiences who may no longer engage with traditional media in the way that previous generations enjoyed. Influencer-generated content has become part of a mixed media diet as the media landscape continues to splinter.


  1. Five hundred hours of content are uploaded to YouTube and 35,000 Instagram Stories go live every minute of the day[6]. Consumers turn to influencers to help them cut through this content clutter and to make sense of what information is important to them.


Social media influencers: beyond advertising and consumerism

Question: Is it right that influencers are predominantly associated with advertising and consumerism, and if not, what other roles to influencers fulfil online?


  1. One output of a firm, organisation, government or NGO collaborating with an influencer is monetisation - specifically the creation of revenue from content published to social media platforms by influencers.


  1. There are three main business models under which influencers operate in collaboration with firms et al.
    1. Affiliate marketing - an endorsement marketing strategy where influencers are treated as affiliates and paid money when users click on their customised URLs. An example of this practice is where an influencer promotes a discount code on Instagram. Here the influencer may earn a commission for every item purchased through that code.
    2. Gifting - where the advertiser offers gifts of services in return for content or a mention posted to social media by an influencer. This might include gifted cosmetics by a cosmetic company or a free hotel stay, meals or spa treatment in return for an online endorsement from the influencer.
    3. Endorsement deals - the influencer acts as a brand ambassador and receives money payment in return for advertising as indicated by the brand.


  1. These three business models are based on the influencer marketing goods or services. However, influencers are not confined purely to commercial endeavours. Influencers play the role of trusted individuals in the online community. They are trusted because they present themselves as authentic, approachable, and relatable individuals.


  1. With growing utilisation of social media platforms such as Instagram, YouTube and TikTok firms, organisations, governments and NGOs increasingly identify influencers as a means by which to connect with previously hard-to-reach stakeholders. Listed below are several examples of influencer collaboration which were designed to carry important messaging and affect positive social change:


  1. The Department for International Development worked with influencers via the Humanitarian-to-Humanitarian (H2H) Network “to help spread accurate health information and reach younger online audiences that are more susceptible to fake news”[7].


  1. The government worked with influencers as part of its test and trace communications programme to inform the public about the programme[8].


  1. The Finnish government reclassified influencers as ‘critical operators’ during the early onslaught of Covid-19 in March 2020. Influencers were considered to possess the ability to connect with young people - those who may not get their news from traditional media outlets[9].


  1. Influencers responded to open briefs issued by both the United Nations and the World Health Organisation to carry important Covid-19 pandemic-related information messaging including personal hygiene, social distancing, know the symptoms, myth-busting[10].


  1. Influencers are being sought out within the realm of political campaigning. Michael Bloomberg and Joe Biden highlighted the power of influencers as a communications tool for political campaigning in their bids to become the 46th president of the United States[11].


  1. US president Barack Obama engaged YouTube influencers in campaigns related to social responsibility back in 2017 when he and then Vice President Biden launched the Digital Influencer Summit.[12]


  1. Siemens’s #GetCheckedChallenge campaign raised awareness during Breast Cancer Awareness month.


  1. The Body Shop worked with influencers as part of its “Forever Against Animal Testing” campaign which generated 8.3 million petition signatures that the cosmetic company then presented to the the United Nations offices. The company is calling for a global ban on the practice of animal testing in cosmetics[13].


  1. Prorail, the Dutch organisation charged with maintaining the railway infrastructure in the Netherlands worked with influencers to reduce the number of railway-related casualties on the network.[14]


  1. In 2017 NATO included influencers as part of the official press pack during training exercises in Romania. This demonstrated a subtle programme of geopolitics. Winning support for NATO from younger generations of Romanians through an influencer marketing campaign fronted by comedians was considered preferable to demonstrating military might.


Influencers and technology

Question: How are tech companies encouraging or disrupting the activities of influencing?


  1. Influencer marketing-focused technology companies enable advertisers to connect with highly relevant social media users. Technology can assist advertisers throughout the influencer marketing workflow but especially during the identification, selection, vetting and recruitment phases of influencer collaboration.


  1. For example, through the use of technology advertisers can interrogate an influencer's data analytics including:
    1. The number of followers an influencer possesses
    2. The level of engagement each social media post typically generates
    3. The age profile, gender and geographic location of the audience
    4. The type and subject matter of each post
    5. The number of views each post receives
    6. Whether the influencer has sought to artificially inflate their level of influence through the purchase of followers or engagement counts in the pursuit of earning higher advertiser fees.


  1. Technology providers enable influencers to share with advertisers their audience and content analytics in real-time. This transparency of API data helps, in turn, to professionalise the industry.


  1. It is worth noting, however, that to effectively connect with specific audiences, it is not sufficient to rely on quantitative data alone. Advertisers should consider human behaviour, interests and relatability. Ahead of selecting an influencer, advertisers should consider such qualitative characteristics such as their shared world-view, a complementary creative style and a positive brand sentiment. In short, advertisers should be powered by data but guided by insights, intellect and human instincts.


  1. Regulators should not rely on social media platforms to enforce arrangements between advertiser and user. Social media platforms serve as both distributor of influencer content and competitor to advertiser and influencer commercial partnerships. For example, Instagram has recently announced plans to create a marketplace so brands can connect with influencers they may want to pay to promote their products to.[15] Leaving enforcement to social media platforms would hand over jurisdiction to private entities and may result in perverse outcomes of unintended consequences.


Consumer awareness of influencer marketing regulation

Question: How aware are users of the arrangements between influencers and advertisers? Should policymakers, tech companies and influencers and advertisers themselves do more to ensure these arrangements are transparent?


  1. There are four categories of awareness of arrangements for influencer marketing-centric tech companies, advertisers and influencers:
    1. Unaware of arrangements (Non compliant) - Fail to effectively disclose influencer marketing as advertising material, as a result. This category represents a diminishing section as the industry professionalises.
    2. Partially aware (Partial compliant) - Aware of the rules and regulations but are not sufficiently competent at satisfying all of these requirements in practice.
    3. Aware (Non compliant) - Aware of the arrangements but current sanctions, or the implementation of those sanctions by regulators, are deemed an insufficient deterrent. This minority fails to effectively disclose influencer marketing as advertising material, as a result.
    4. Aware (Fully compliant) - The advertiser, their agent and the influencer are fully aware of the requirements surrounding influencer marketing and ensure all elements are fully complied with.


  1. Whilst compliance with requisite arrangements is the legal, ethical and reputationally correct position compliance has commercial benefits, as well. More than half of US consumers (53%) are likely to consider brands that are transparent on social for their next purchase. However, a lack of transparency on social leaves 86% of people likely to take their business to a competitor[16]. The IMTB is a supporter of promoting best practices in every quarter of influencer marketing including disclosure arrangements to its members, the influencers its members collaborate with, and so protecting society at large.


  1. As in other advertising disciplines, speed of adoption, ultimate utlisation and proficient use of specifics contained within the arrangements between advertisers and users are often slow. For example, seven years after TV programmes made for UK audiences were allowed to contain product placement as long as they complied with Ofcom's rules fewer than one-in-three (30%) of viewers recalled seeing the P symbol, that denotes placement is coming up in the proceeding show. Only 22% knew what the symbol meant.[17]


  1. The ASA and CAP annual report 2020[18] published on April 29th 2021 shows a decrease of 8% in the number of complaints made against influencer-generated advertisements. The report shows a 9% reduction in the number of influencer-generated advertisements cases investigated by the ASA. The number of complaints and resulting cases remains high, however it is hoped that 2019 represents the highwater mark in terms of complaints and cases and that the downward trend is set to continue.


  1. Awareness of arrangements is thanks to initiatives undertaken by both the CMA and the ASA. It is also thanks to best practice being promoted within the industry by progressive practitioners, many of whom are members of the IMTB. The ASA noted in March it was “heartened to see large elements of the [influencer marketing] industry maturing and disclosing ad content transparently.”[19] However, the ASA also noted more needs to be done with “too many incidences of non-disclosure” still occuring. It is in the influencer marketing industry’s best interests to ensure compliance with advertising rules. Failure to comply risks diminishing the impact of this nascent discipline by bringing it into disrepute and by breeding distrust in consumers. To that end we, the IMTB, are actively working on incorporating a code of conduct covering disclosure matters for our members.


  1. It is our position that current compliance and disclosure rules are sufficient and fit-for-purpose.


  1. Furthermore it is our position that awareness of current compliance and disclosure rules and regulations are sufficiently well understood by consumers.


  1. However, sanctions at the disposal of the regulators and the process for triggering those sanctions may need to be revisited. The ASA report published in March[20] detailed findings of a monitoring exercise of 122 UK-based influencers to assess whether advertising content was being properly disclosed. The monitored “influencers were primarily chosen on the basis of having been previously contacted about non-disclosure of advertising by the ASA.” The findings showed a significant proportion of the content produced by these 122 influencers failed to satisfy arrangements. This suggests that these influencers, whilst being aware of the arrangements, had taken a commercial decision not to abide by them.


  1. The industry should work in concert with regulators and self-regulators to amend or alter rules and regulations. The IMTB seeks to be part of those ongoing discussions to ensure consumers continue to enjoy protection from misleading or covert advertising. 






[1] Insider Intelligence (2021, January 06) Influencer Marketing: Social media influencer market stats and research for 2021. Retrieved 29 April 2021 from https://www.businessinsider.com/influencer-marketing-report

[2] Bespoke research undertaken by Global Web Index and published within a 2019 trends report titled: ‘Influencer Marketing: Exploring the current influencer marketing landscape and its future potential’.

[3] Influencer Marketing Hub (2021, February 15) The State of Influencer Marketing 2021: Benchmark Report. Retrieved 29 April 2021 from https://influencermarketinghub.com/influencer-marketing-benchmark-report-2021/

[4] Katz, E., & Lazarsfeld, P. (1955). In Personal Influence: The part played by people in the flow of mass communications. New York: The Free Press.

[5]  Goanta, C. and Ranchordas, S. (2020) The Regulation of Social Media Influencers published by Edgar Law p.7.

[6] Statista. (2020, September 21). A Minute on the Internet in 2020. Retrieved April 21, 2021, from https://www.statista.com/chart/17518/data-created-in-an-internet-minute/

[7] Department for International Development. (2020, March 12). Press release: UK aid to tackle global spread of coronavirus ‘fake news’. Retrieved April 21, 2021, from https://www.gov.uk/government/news/uk-aid-to-tackle-global-spread-of-coronavirus-fake-news

[8] BBC News Business. (2020, August 31). Love Island stars and influencers paid to promote Test and Trace. BBC News. Retrieved April 21, 2021, from https://www.bbc.co.uk/news/business-53968222

[9] The Guardian. (2020, April 01). Finland enlists social influencers in fight against Covid-19. https://www.theguardian.com/world/2020/apr/01/finland-enlists-social-influencers-in-fight-against-covid-19 

[10] Delahunty, S. (2020, March 19). Influencers urged to support WHO social distancing message. PR Week. Retrieved April 21, 2021, from https://www.prweek.com/article/1677568/influencers-urged-support-social-distancing-message

[11] Heilweil, R. (2020, September 22). Inside the Biden campaign’s surprising influencer strategy. Recode. Retrieved April 22, 2021, from https://www.vox.com/recode/21429755/influencers-joe-biden-democrats-pacs-social-media-facebook-instagram-campaign

[12] Davis, B. (2017, January 11) Joe Biden Welcomes Youtube’s Top Influencers To The White House. Resource. Retrieved April 29, 2021 from http://resourcemagonline.com/2017/01/joe-biden-welcomes-youtubes-top-influencers-to-the-white-house/73493/

[13] Muxworthy, L. (2018, October 06). 8.3 million signatures call for end to cosmetic animal testing. news.com.au. Retrieved April 21, 2021, from https://www.news.com.au/lifestyle/beauty/83-million-signatures-call-for-end-to-cosmetic-animal-testing/news-story/1ec0fc9582204e0a15fc4cc8785bf995

[14] Influencer Marketing Awards. (2020, March). Most creative influencer marketing campaign. Influencer Marketing Awards. Retrieved April 21, 2021, from https://influencermarketingawards.com/winners/#most-creative-influencer-marketing-campaign

[15] Bloomberg. (2021, April 27) Instagram to Create Marketplace for Influencers’ Brand Deals. Retrieved May 03, 2021, from https://www.bloomberg.com/news/articles/2021-04-27/instagram-to-create-marketplace-for-influencers-brand-deals

[16] SproutSocial: #BrandsGetReal: Social media & the evolution of transparency. Retrieved May 03, 2021, from https://sproutsocial.com/insights/data/social-media-transparency/ 

[17] TRP Research. (2018, May 01) 7 Years On: Uk Viewers Positive About Product Placement …but Could It Be Used More? Retrieved May 03, 2021 from https://www.trpresearch.com/7-years-on-uk-viewers-positive-about-product-placement/

[18]  (2021, April 29) Protecting young and vulnerable people: Annual Report 2020 - Advertising Standards Authority and Committees of Advertising Practice. Retrieved April 29 2021 from https://www.asa.org.uk/uploads/assets/0067e136-d553-4195-b0d8e93dede527df/ASA-CAP-2020-Annual-Report.pdf?dm_i=4PDW,HSP6,172FFM,23TUN,1

[19] Influencer Ad Disclosure on Social Media. (2021, March 18). Advertising Standards Authority. Retrieved April 21, 2021, from https://www.asa.org.uk/uploads/assets/dd740667-6fe0-4fa7-80de3e4598417912/Influencer-Monitoring-Report-March2021.pdf

[20] Influencer Ad Disclosure on Social Media. (2021, March 18). Advertising Standards Authority. Retrieved April 21, 2021, from https://www.asa.org.uk/uploads/assets/dd740667-6fe0-4fa7-80de3e4598417912/Influencer-Monitoring-Report-March2021.pdf