Written evidence submitted by the Department for Digital, Culture,
Media and Sport





  1. The Government is pleased to respond to the Digital, Culture, Media and Sport Select Committee’s inquiry into Influencer Culture. We look forward to the Select Committee’s evidence and recommendations on this subject.



  1. While influencers can have a positive effect, we also need to consider how the ‘influencer as advertiser’ model works and if this space is adequately regulated to protect the public and consumers. We must also consider that there are bad actors who may use influencer culture as a means to promote hate or harm.


How would you define ‘influencers’ and ‘influencer culture’? Is this a new phenomenon?

  1. Influencers are not a new phenomenon, but connectivity has heightened the role that influencers play in our lives. Digital technologies can blur the borders between what is authentic and what is not. It is not always clear that content has been staged to promote products/services on behalf of a third party. This can create an illusion of intimacy between a ‘follower’ and an influencer.

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

  1. Influencers can bring positive effects to society through campaigning and advocacy work. Influencer culture can quickly raise consciousness and promote debate about how society operates, how people think about issues and help people connect and find support. However, social media and influencer culture can also promote false views of what is normal, in terms of appearance, lifestyle and success. This can make people feel like they do not measure up, leading to lower self-esteem. Although many images are staged, the volume and pervasive nature of the medium can influence how people think and feel about themselves to the extent that people forget what they are seeing is not authentic.

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

  1. Influencers fulfil a wide range of functions and as a result it is difficult to distil this down to one specific area. However,  there are instances where influencers use their platform to advertise, for example, promoting products or services to their ‘followers’ in exchange for monetary or non-monetary benefits from a business.


  1. The Advertising Standards Authority (ASA) regulates advertising online, through the committee of non-broadcast advertising and direct & promotional marketing code (CAP Code). They have acted proactively to address this. For example, by creating ‘influencer cheat sheets’ which provided guidance on the advertising rules for “Love Island” contestants who were likely to be offered advertising contracts upon leaving the show. The ASA works closely with the Competition and Markets Authority (CMA), who have recently conducted a report on Social Media Endorsements.


  1. Young people and adults have highlighted that social media can impact their body image in a positive way. Social media provides the opportunity to ‘follow’ a diverse range of people and see influencers of a variety of abilities, genders, ethnicities and body shapes. People have praised that adverts on social media can also be more diverse and more representative, for example showing stretchmarks and body hair, compared to adverts in mainstream media. While young people can feel pressured by idealised representations on social media, conversely they are also finding collective support through groups and non traditional mediums.


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

  1. Social media services can be used to facilitate harm, including through influencers’ activity on those services. Social media companies have their own terms of service (or ‘Community Standards’) which limit what all users (including influencers) can post on their platforms. This can disrupt influencer activity where that activity violates certain standards.


  1. The new Online Safety legislation will require companies to identify and tackle illegal content on their platforms, and protect children from harmful content and activity online. Although not specifically targeted at influencers, this will include influencer content where it is illegal or harmful to children. In addition, the most popular social media companies will need to state how they will handle content, which may include influencer content, which is legal but could cause significant physical or psychological harm to adults. These services will be required to set out clearly to users on their platform what is acceptable on their services and enforce their own terms and conditions consistently and transparently.


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. Following a call for evidence last year, work on the Online Advertising Programme will resume shortly. This was paused due to essential work on Covid-19. The Government has committed to undertake a consultation before the end of this year. This will focus on addressing harms caused within the content and/or placement of advertising online, including influencer advertising. We anticipate this work will include looking at the role of online platforms in the regulation of advertising online, which will include platforms such as Instagram, YouTube, Facebook, Twitter, and TikTok.


  1. The Government through this work will consider the extent to which the current regulatory regime is equipped to tackle the challenges posed by the rapid technological developments seen in online advertising. We will consult on a range of interventions to strengthen the regulatory framework to reduce the occurrence of harms and address the role of online platforms.


  1. Both the ASA and the CMA aim to think more broadly in terms of behaviour change through training for the sector. The ASA has recently published a report on Influencer Advertising which highlights steadily rising complaints about whether influencer adverts are appropriately disclosed on social media. In 2020, the ASA has analysed over 24,000 individual pieces of content on Instagram across 122 UK-based influencers. The results highlighted a disappointing overall rate of compliance with existing advertising rules on making sufficiently clear when they were being paid to promote a product or service. Following these findings the ASA wrote to all of the Influencers monitored and the main brands who had partnered with one or more of the influencers. Brands are held equally responsible for failing to adequately disclose advertising content where they may be working with influencers. The ASA requested that the influencers provide an assurance of future compliance with the rules and will undertake monitoring to ensure that they comply or face sanctions.


  1. Media Smart the advertising industry's media literacy programme helps young people understand advertising they come across in their everyday life and in turn critically evaluate what they see online, including influencer content.


  1. In October 2020, Facebook Ireland Limited (Facebook) committed to the CMA that it will do more to prevent hidden advertising being posted on its Instagram platform. The CMA has been investigating Instagram due to concerns that it was not doing enough under UK consumer protection law to prevent its users from endorsing businesses without making it clear that they had been paid or given free gifts to do so. Hidden advertising is illegal in the UK under the Consumer Protection for Unfair Trading Regulations. Instagram has committed to the CMA that it will revise and make clearer its policies governing the publication of incentivised endorsements and, importantly, uphold its Terms of Use which include the deletion of posts or termination of user accounts that are found to have breached these policies. The CMA will continue investigating the practices of other social media platforms to ensure that changes are made where necessary.


  1. The Home Office monitors social media and influencer activity and encourages tech companies to play their part in preventing terrorist use of the internet. Terrorist groups and individuals actors can use the internet to spread propaganda designed to radicalise and recruit people, and to incite and enable terrorist attacks.  The Government changed the law through the Counter-Terrorism and Border Security Act 2019, so that people who view terrorist content online could face up to 15 years in prison. This change strengthens the existing offence, so that it applies to material that is viewed or streamed online.