Influencer ad disclosure in Türkiye and the Netherlands

In both Türkiye and the Netherlands, a post an influencer makes in return for money, products or any other benefit is expected to be labelled as advertising in a way followers recognise at first glance. The details vary by country and platform and are updated over time. This article gives a general overview; it is not legal advice, and we recommend checking the current texts with a legal adviser before a campaign.

Türkiye: the Ministry of Trade influencer guidance

The Advertising Board of the Ministry of Trade published guidance on commercial advertising by social media influencers in 2021. At the time of writing, its core principle is that where there is a commercial relationship between influencer and advertiser, it must be disclosed so that consumers can easily recognise it.

The general approach can be summarised as follows:

• The disclosure should appear at the start of the post, clearly and in Turkish, using plain terms such as "reklam" (advertisement) or "işbirliği" (collaboration).
• It should not be hidden behind a "see more" link or among many hashtags.
• In videos and live streams, disclosure is expected visually and, where relevant, verbally, long enough to be noticed.
• Gifted products can also count as a commercial relationship.
• The guidance can place responsibility not only on the influencer but also on the advertiser and intermediary agencies.

For exact rules, example wording and possible sanctions, consult the current text on the Ministry's website.

The Netherlands: advertising code, consumer law and the CvdM

The Dutch framework has several layers. The Stichting Reclame Code's advertising code for social media and influencer marketing (Reclamecode Social Media & Influencer Marketing) requires paid or incentivised posts to be clearly disclosed and suggests example labels. It is self-regulation; complaints go to the Advertising Code Committee.

Hidden advertising can also be an unfair commercial practice under consumer law, which the consumer authority ACM enforces. In addition, the Dutch Media Authority (Commissariaat voor de Media) registers large video creators who meet certain criteria, such as follower numbers and publishing regularity, and applies media-law rules on advertising and the protection of minors to them. The criteria can change, so check the current position on the CvdM website.

Practical labelling advice

1. Put the disclosure in the first line of the post, in the language your audience understands: Turkish for a Turkish audience, Dutch or the audience's language for a Dutch one.
2. Use the platform's own "paid partnership" feature, but do not rely on it alone; state it in the text too.
3. In videos, show the label on screen and in the caption; in stories, keep it visible on every frame.
4. Disclose gifted products as well.
5. For campaigns targeting both countries, set one standard that meets both sets of expectations.

Contracts and usage rights

Disclosure obligations belong in the contract: which wording is used, where and how, brand approval before publishing, and what happens if the rules are not followed. Verifiable product claims and extra restrictions for regulated categories such as health, finance or alcohol also belong there.

Usage rights are a separate topic. If the brand wants to reuse content on its own social channels, website or in paid ads, duration, channels and territory must be defined. Content reused in paid ads must remain clearly identifiable as advertising.

How Grafikare approaches it

During campaign planning we identify the target countries and platforms and build the disclosure rules into the brief and contract framework. Before publishing we check content for correct labelling, and where a legal interpretation is needed we refer our client to their own legal adviser.