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Freedom251 › Blog › advertising compliance

A Practical Checklist for Reviewing Game Advertising and Influencer Promotions (2026)

By Freedom251 Team · · 9 min read

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Review a game promotion in two layers: first verify that the game’s claims and the creator’s apparent experience are truthful and supportable; then verify that every payment, gift, commission, or other relationship is clearly disclosed where the endorsement appears. Add separate checks for children’s exposure, in-game purchases, platform format, and the jurisdiction governing the placement.

What this checklist covers

Game marketing can combine a store listing, a trailer, a creator’s gameplay, a discount code, affiliate links, and a livestream. Each element can communicate an advertising claim, even when nobody says “I recommend this game.” A review therefore has to examine both the advertiser’s statements and the creator’s words, images, conduct, and audience.

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The U.S. baseline is the Federal Trade Commission’s Endorsement Guides and related staff guidance. The FTC describes an endorsement as an advertising message consumers are likely to believe reflects someone other than the advertiser. Its central rule is that an endorsement must reflect the endorser’s honest opinion and cannot be used to make a claim the marketer could not legally make. The guidance is fact-specific and does not create a safe harbor. This checklist is an editorial control, not legal advice for a particular campaign.

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Step 1: Record the campaign and its governing context

Create a campaign record

Before judging the copy, capture the basic facts in one place:

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  • Advertiser, game title, developer or publisher, and creator names.
  • Campaign format: store listing, paid social post, short video, long-form video, livestream, trailer, display ad, or linked landing page.
  • Publication date, planned run dates, target market, language, and distribution platforms.
  • Whether the creator is paid, receives a commission, gets free or early access, receives virtual currency or items, or has another relationship with the advertiser.
  • The intended audience and the audience likely to encounter the placement, including children.

Save the exact version reviewed: screenshots, video files, captions, spoken scripts, thumbnail art, links, discount codes, and the store description. A later edit can change the disclosure or a material claim without changing the campaign name.

Separate jurisdictions

Identify the law and advertising codes that can apply to each audience and platform. FTC staff says U.S. law may apply to a post made abroad when effects on U.S. consumers are reasonably foreseeable; the law of the creator’s or audience’s country may also apply. Do not treat a U.S. review as clearance for a UK, EU, or other market.

Record whether the placement is an app-store listing, an in-game message, a social post, or creator content. The UK ASA/CAP loot-box notice described below has a much narrower scope than general endorsement guidance.

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Step 2: Test claims against evidence and the creator’s real experience

Check objective game claims

List every verifiable statement and request evidence from the advertiser. Check claims about:

  • Features, modes, cross-play, device compatibility, accessibility, and technical performance.
  • Price, discounts, availability, release timing, regional access, and subscription terms.
  • Rewards, progression speed, drop rates, competitive outcomes, or earnings.
  • Player counts, review scores, awards, or comparisons with another game.

Evidence should match the version and region shown in the ad. A feature in a test build does not prove that it is available to the audience seeing the promotion. If a price is temporary, state the dates and conditions in the ad rather than presenting it as the ordinary price.

Check what the creator actually experienced

A creator’s gameplay, facial reaction, thumbnail, tags, or other conduct can communicate approval without an explicit recommendation. Compare the published material with the access the creator received. Ask whether the creator played the released build, the advertised platform, and the relevant game mode. Do not let an edited highlight imply a result or experience the creator did not have.

Claims about exceptional results need special care. If a creator shows unusually fast progression, a rare item, or an extraordinary competitive result, the advertiser needs support that the result is generally achievable or must clearly disclose the generally expected result when the law requires it. A disclaimer that is hidden in a description does not cure an emphatic on-screen implication.

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Mixed or negative reviews still require disclosure

A paid review remains an endorsement even when it includes criticism. Negative comments do not cancel a material connection. Reviewers should be free to express an honest opinion, but the sponsorship relationship still has to be clear and the advertiser cannot use the review to make an unsupported claim.

Step 3: Identify every material connection

A material connection is any relationship that could affect how an audience evaluates the recommendation and that viewers would not reasonably expect. Money is only one possibility. Use this inventory for each creator:

Connection What to verify Editorial action
Cash fee or salary Flat fee, per-post payment, bonus, or continuing retainer Require a prominent sponsorship disclosure with the endorsement
Affiliate commission Tracking link, referral code, or revenue share Disclose the commission relationship, not merely the existence of a link
Free, discounted, or early access Review copy, closed test access, premium edition, or free subscription Disclose the benefit when it could affect the audience’s judgment
In-game value Virtual currency, cosmetic items, loot-box credits, or boosted accounts Describe the incentive in plain language where relevant to the endorsement
Travel or equipment Press trips, events, loaned hardware, or production support Assess whether the benefit is material and disclose it
Employment or business relationship Creator is an employee, contractor, investor, or ongoing partner Make the relationship clear in the content itself
Personal or family tie Relative, close friend, or other personal connection to the advertiser Disclose the tie if it could affect credibility

FTC staff places responsibility on the influencer: “As an influencer, it’s your responsibility to make these disclosures, to be familiar with the Endorsement Guides, and to comply with laws against deceptive ads. Don’t rely on others to do it for you.” An old disclosure on a previous post does not automatically cover a new endorsement; check every placement.

Step 4: Make the disclosure impossible to miss

Use plain, understandable wording

Use simple terms such as “Ad,” “Advertisement,” or “Sponsored,” in the same language as the endorsement. Explain an affiliate relationship when that is the connection, for example that the creator may earn a commission from a code or link. Avoid vague labels that viewers may not understand, such as an unexplained abbreviation or a brand-only tag.

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Put it with the endorsement

The disclosure should appear where viewers encounter the recommendation. Do not rely only on a profile or “about” page, text hidden after a “more” break, the end of a long post or video, or a cluster of hashtags and links. A platform’s paid-partnership tool can supplement a clear disclosure, but it should not be treated as an automatic substitute.

Apply format-specific placement

Format Minimum review questions
Static post or image Is the disclosure visible before or alongside the endorsement, without expanding the post or searching through tags?
Short video Does the video itself display and, where practical, say the disclosure early enough for viewers who do not open the description?
Long-form video Is the relationship disclosed in the video, not only in the description, and repeated if the endorsement returns later?
Livestream Does the host disclose at the start and repeat the disclosure periodically so people joining midstream are informed?
Store listing or landing page Can a consumer see the commercial nature and important purchase conditions before downloading or buying?

For video, consider both visual and spoken disclosure. Viewers may watch without sound, miss small text, or join after the first seconds. For a livestream, schedule recurring on-screen or spoken notices rather than assuming every viewer heard the opening.

Step 5: Review children’s exposure separately

Ask whether the ad looks like ordinary gameplay

Younger children and some neurodivergent children can have difficulty distinguishing advertising from entertainment or gameplay. Check whether branding, paid segments, product demonstrations, and calls to buy are visually and verbally distinguishable from the creator’s ordinary stream. A disclosure that an adult understands may still be unclear to a child.

Do not treat parental controls as an advertising solution

FTC consumer guidance says most parental controls focus on content and time restrictions. They generally do not provide a dedicated control for ads children encounter while searching for, downloading, or playing games. Document ad visibility as its own issue instead of assuming a family setting removes the risk.

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Keep ratings and spending controls distinct

Review age ratings, ad exposure, and purchasing controls as three separate checks. Device and platform settings may restrict game ratings or in-game purchases, including virtual currency and loot boxes, but those settings do not establish that the advertisement itself is suitable or accurately labeled. Confirm that instructions for parents match the platform and operating system shown in the campaign.

Step 6: Audit loot-box and random-item representations

Determine whether the UK notice applies

The ASA/CAP enforcement notice dated 26 February 2026 covers Apple App Store and Google Play listings within CAP’s remit for mobile games that contain loot boxes purchasable with real money or with virtual currency obtainable only through purchase. It is not a universal rule for every store, platform, country, or game format. ASA/CAP said active monitoring began on 26 May 2026.

When the notice applies, consumers must know before purchasing or downloading whether the game contains loot boxes. Check the listing’s description, screenshots, and expandable sections—not just the ad creative.

Use a specific, prominent statement

Examples given by ASA/CAP include “contains loot boxes” and “includes random-item purchases.” Place the statement prominently near the top of the game description. Do not rely on an expandable text area or a generic “offers in-app purchases” label; that wording does not explain that a purchase can produce a random item.

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ASA/CAP states in this guidance that loot boxes are not recognised as gambling under UK law, while also reporting firm action against ads for games that include them. Do not describe loot boxes as legally gambling in the UK based on this notice alone. Record the purchase route—real money or purchase-only virtual currency—because that fact determines whether the notice’s stated scope is met.

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Step 7: Compare campaigns using the same axes

When several creators or versions are under review, use one worksheet rather than separate informal judgments. Compare each campaign on these dimensions:

Axis Questions to answer
Jurisdiction and platform Which audience, store, social network, and national rules are implicated?
Audience Who is intended to see it, who is likely to see it, and are children likely to be present?
Connection What payment, gift, commission, access, employment, or personal tie exists?
Claims What objective and outcome claims appear, and what evidence supports each one?
Disclosure What wording is used, where does it appear, when does it appear, and can it be missed?
Format risk Does the placement require spoken and visual disclosure, recurring livestream notices, or store-listing language?
Purchase mechanics Are loot boxes, random rewards, virtual currency, prices, and conditions described accurately?

Mark each axis pass, revise, or escalate. Escalate when the governing jurisdiction is uncertain, evidence for a material claim is missing, a child audience is substantial, or the commercial relationship cannot be explained in plain language.

Common failure modes and practical fixes

“Everyone knows this creator is sponsored”

Audience familiarity is not a substitute for a disclosure. Add a clear label in the post or video and repeat it when the format requires repetition.

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Disclosure hidden in hashtags or after “more”

Move the notice next to the endorsement, before the viewer must expand the content. Keep the wording readable on a phone.

Only the description discloses a video sponsorship

Put the disclosure in the video itself, using both visible text and spoken words when feasible. Check the result with sound off and at normal mobile size.

Generic in-app-purchase language for a loot-box game

For a UK listing within the ASA/CAP notice’s scope, replace or supplement generic wording with a prominent statement that random-item purchases or loot boxes are included.

Assuming a gifted game is not a material connection

Free access, early access, virtual items, travel, and equipment can affect how viewers judge a recommendation. Record the benefit and require disclosure when it could influence credibility.

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Relying on a parental-control setting

Verify ad visibility, age rating, and spending controls independently. A setting that blocks purchases may not block the ad that promotes the game.

Final sign-off record

Keep the completed checklist with the approved creative and evidence. The reviewer should be able to show:

  • Which claims were checked and what evidence supported them.
  • What the creator received or stood to receive.
  • The exact disclosure wording and its position in each format.
  • The audience, child-exposure assessment, and controls checked.
  • The jurisdictional basis for any UK loot-box statement or other platform-specific decision.
  • Who approved the material, on what date, and which version was approved.

Re-run the review after edits to the game, store description, creator script, pricing, purchase mechanics, audience targeting, or platform placement. FTC guidance depends on the facts of the particular communication, and the ASA/CAP notice applies only within its stated boundaries.

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Product prices and availability are accurate as of the date/time indicated and are subject to change. Any price and availability information displayed on Amazon at the time of purchase will apply.

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