Response by the Influencer Marketing Trade Body to oral evidence provided on 13 July 2021.


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



13    August 2021



Virtual influencers


1.                  The subject of virtual influencers was raised during the questioning of Keith Weed on 13th July as part of the committee’s oral evidence. The hacking of one virtual influencer’s Instagram account, Lil Miquela, by rival virtual influencer, ‘Bermuda’ was mentioned. This hack was a stunt. Both Bermuda and Lil Miquela are the creations of Brud, a Los Angeles-based firm. This ‘hacking’ highlights two interlinked issues: (i) Transparency of ownership. (ii) Motivation for ownership. The stunt took place during a $6 million investment round into Brud. The round closed successfully shortly after this event. Post stunt Bermuda’s audience swelled from 2,000 Instagram followers to over 50,000.


2.                  There are advocates within the industry – the Influencer Marketing Trade Body (‘IMTB’) included - who believe virtual humans should be watermarked. The mark would designate three pieces of information to protect consumers:


    1. Disclosure - The virtual human is virtual, not human.
    2. Ownership - The details of its owner.
    3. Motivation - The motivations driving the creation of this content.


3.                  In July 2021 the Advertising Standards Council of India (ASCI) launched influencer marketing guidelines which include provision for treatment of virtual influencers. ASCI noted that “a virtual influencer must additionally disclose to consumers that they are not interacting with a real human being. This disclosure must be upfront and prominent”. This measure supports item 4a above.


4.                  Most current avatar influencers are reliant on scripts and human interaction. They are unable to think for themselves. Their Instagram captions are carefully written on their behalf. Their online presence is manufactured by human designers. However, the next wave of avatar influencers will be unshackled by pre-scripted animation paths. They will be able to operate at scale without being reliant on human intervention. They will learn from each human interaction and will have the propensity to become more useful in each future human interaction.


5.                  During the oral evidence session on 13th July DCMS committee member Mr. Giles Watling reasoned with Mr. Weed that firms might build their own virtual influencers. This is already the case. Luxury French fashion house Balmain created virtual influencers solely to model its product line. Other brands have turned to virtual influencers to become virtual brand assistants. Procter and Gamble’s global prestige skincare brand, SK-II, worked with YUMI - a fully autonomous AI driven, synthetic human capable of interacting as a human. YUMI was designed to help consumers better match their skin types to SK-II products and to provide tips and advice on beauty product application.



Influencers’ freedom of expression


6.                  With regards to Prof. Jonathan Hardy’s written testimony which touched on brand safety and an influencer’s freedom of expression: increasingly influencers vet brands for appropriateness as much as brands vet influencers. The selection process is a two-way street. Influencers who desire a long-term career within this space seek to work with brands that reflect the same values and worldview as them. Ultimately influencers are influential due to the community they connect with. If that community feels as though the influencer is not being true to his/her beliefs or ‘authentic’ in the content produced the community will ‘call out’ that influencer and potentially unfollow them. It is therefore in the interests of both advertiser and influencer to form a relationship based on mutual values and outlook. The most effective influencer campaigns tend to be co-created between advertiser and influencer rather than advertisers being overly prescriptive in shaping the messages that are circulated on their behalf. 


7.                  The Influencer Marketing Trade Body is a newly-formed professional membership organisation for influencer marketing agencies and influencer marketing platforms. We are dedicated to building a robust, sustainable future for the influencer marketing industry. More information, including our code of conduct, may be found at