IAB Croatia releases comprehensive influencer marketing disclosure guidelines

IAB Croatia published comprehensive guidelines on November 3, 2025, establishing self-regulation standards for influencer marketing disclosure across digital platforms. The organization launched the framework alongside a national campaign titled "Važno je znati kad se plati" (It's Important to Know When It's Paid), marking what industry members describe as a significant step toward transparency in commercial partnerships between content creators and brands.

The guidelines emerged from a working group comprising industry professionals, academics, media representatives, and civil society organizations. Mario Fraculj, a member of IAB Croatia's Self-Regulation Working Group for influencers, stated that digital communication shapes values and trust across society, making ethical standards essential rather than optional.

According to the documentation, the initiative addresses widespread opacity in influencer marketing practices. Research cited in the guidelines indicates only 20 percent of consumers recognize influencer content as commercial messaging. The framework aims to increase public trust and encourage responsible behavior from influencers, advertisers, and agencies.

Primary disclosure requirements

The guidelines establish mandatory labeling protocols for paid partnerships. Content creators must use primary markers including "oglas" (advertisement), "promo" (promotion), "plaćeno" (paid), or "ad" for English-language posts. These labels require prominent placement at content beginnings, separated through typographic solutions or distinct graphic presentations.

Platform-provided disclosure tools, such as Instagram's "Paid partnership" feature, satisfy requirements when clearly visible and prominently displayed. The framework recognizes these autoregulation mechanisms as sufficient for compliance.

Secondary markers including "#suradnja" (collaboration), "#AmbasadorBrenda" (brand ambassador), "#Sponzorirano" (sponsored), and "#Affiliate" may supplement primary labels but cannot replace them. The guidelines explicitly discourage ambiguous phrases such as "U suradnji s" (in cooperation with), "U partnerstvu s" (in partnership with), and "Hvala [brendu] što je omogućio" (thanks to [brand] for enabling).

The working group emphasizes that disclosure obligations extend beyond financial compensation. Benefits triggering disclosure requirements include monetary payments, commissions, discounts, complimentary products, or any consideration expressible in monetary terms. This encompasses gifts, travel, accommodation, recreation, and similar protections.

Platform-specific implementation

The documentation provides explicit formatting examples across major social networks. Instagram and Facebook content requires typographic or iconographic labels at post beginnings. TikTok videos necessitate visible markers throughout content duration. YouTube presentations demand clear labeling in both visual frames and description fields.

Content classifications requiring disclosure encompass advertising, reviews based on provided benefits, sponsorships, prize competitions, brand ambassador roles, discount codes, affiliate links, and all materials with fundamentally commercial purposes. The framework establishes that content promoting creators' own products or self-promotion without commercial interests does not require disclosure.

Exceptions exist for cultural, scientific, humanitarian, and educational purposes, which should be identified as such. Publicity and donor activities without commercial interests remain outside disclosure obligations. Reposted content from brand pages requires disclosure when commercial interests exist.

The Digital Services Act implementation across Europe has increased scrutiny of advertising transparency. A February 2024 investigation by the European Commission and national consumer protection authorities revealed widespread failures by influencers to disclose paid content, prompting regulatory warnings and enforcement actions.

Legal and ethical foundations

Croatian legislation governing advertising and marketing communications applies to influencer activities despite lacking specific provisions for this format. Existing law mandates that advertisements must be clearly marked and visibly separated from editorial content. Advertisements cannot create impressions among viewers, listeners, or readers that content represents editorial material.

Current statutes prohibit concealed and deceptive advertising. The legal framework defines concealed advertising as any form—including written text, photographs, images, or drawings—that is paid but not clearly marked as advertising. Concealed audiovisual commercial communication involves presenting goods, services, names, trademarks, or similar elements in programs through words or images when the media service provider's intention is advertising and could mislead the public regarding its nature.

The ethical framework draws from the International Chamber of Commerce's Advertising and Marketing Communications Code. This foundation underpins self-regulation systems in Croatia through ethical codes maintained by the Croatian Chamber of Economy and the Croatian Association of Market Communication Societies. Influencer marketing should be lawful, decent, honest, and truthful. Communications should be prepared with a sense of social and professional responsibility according to fair market competition principles.

Marketing communications must be clearly distinguishable as such regardless of form or medium. When advertisements or paid content appear in media, designed as news or incorporated into editorial content—including influencer content or native advertising—such content must be presented to be easily recognizable and marked according to platform capabilities.

Communications should not contain or refer to testimonials, confirmations, or similar endorsements unless authentic, verifiable, and relevant. Testimonials that are outdated or misleading should not be used. The sponsored or advertising nature of testimonials or endorsements must be clear through appropriate separation and marking if the form and format would not otherwise be understood as sponsored or advertising messages.

Industry context and growth

Influencer marketing represents one of the fastest-growing segments within digital communications. The industry is projected to reach 32 billion dollars globally by the end of 2025, with annual growth exceeding 10 percent in subsequent years, according to the Influencer Marketing Benchmark Report 2025 cited in the guidelines.

Success in this channel stems from authenticity, versatility, seamless integration, efficiency, and potential for long-term community engagement. Content reaches consumers on social networks where they spend leisure time, fostering authenticity through less intrusive delivery compared to traditional advertising formats. This particularly resonates with millennials and Generation Z. The Morning Consult Influencer Report from 2024 showed 61 percent of respondents trust influencers, increasing from 51 percent in 2019.

However, the format presents challenges for consumers, especially children, youth, and vulnerable groups. Issues range from concealed advertising to false product representation, promotion of dangerous products to marketing unhealthy foods to children, exaggerated product claims, and other unacceptable, illegal, and unethical practices.

European Union regulations governing consumer protection—including directives, regulations, and opinions—partially address these situations but remain insufficiently and inconsistently implemented across member states. The recommended guidelines and their application represent opportunities to strengthen trust in influencers, influencer marketing, and marketing generally while building social responsibility.

Advertising transparency initiatives have accelerated across digital platforms. TikTok implemented AI-generated content disclosure tools in July 2024, while Google and Amazon introduced comprehensive pricing transparency reports in March 2024. These developments reflect growing regulatory pressures and industry self-regulation efforts.

Stakeholder obligations

IAB Croatia issued the guidelines under the umbrella of the Croatian Association of Market Communication Societies (HURA), partnering with the Croatian Association of Digital Publishers (HUDI), the European Commission, the Croatian Public Relations Association (HUOJ), and with support from Solidarna Foundation and the Agency for Electronic Media.

The framework targets influencers, brands, marketing agencies, media, and all actors in the marketing communications industry. For influencers, the document provides primary guidance on transparent and ethical post marking. Brands receive direction on proper collaboration with influencers, ensuring transparency and regulatory compliance. Marketing agencies gain instructions for developing effective and ethical campaigns using influencer marketing while respecting legal frameworks and professional rules.

Media and media professionals play significant roles in influencer marketing. Many influencers use traditional and digital media to extend influence, while journalists and editors frequently follow and report on new trends, campaigns, and influencers. Media maintain responsibility for creating accurate and objective narratives about influencer marketing.

Additional stakeholders include regulatory institutions, consumer rights protection organizations, and all parties addressing legal and ethical aspects of influencer marketing. These actors ensure social network marketing complies with laws and regulations protecting consumers.

The working group calls on all market participants—influencers, brands, agencies, and media—to sign a declaration and begin applying the guidelines. Declaration signatories confirm belief in influencer marketing that is "lawful, decent, honest, and truthful" and advocate for guideline promotion and professional principles.

IAB Europe published measurement guidelines for commerce media on November 3, 2025, the same day as the Croatian influencer marketing framework. The European organization has pursued measurement standardization through multiple initiatives addressing fragmentation, with research indicating 78 percent of stakeholders identify media measurement as requiring industry alignment.

Regulatory environment

While regulations and codes provide fundamental rules, rapid development of digital channels and changes in consumer behavior raise questions requiring contemporary and nuanced solutions. Influencer marketing, as one of the fastest-growing and most influential digital communication segments, proves particularly sensitive to these questions.

Strength lies not only in reach but in influence on shaping attitudes, behaviors, and consumer decisions. Due to this influence level, the need for responsible approaches becomes necessity. IAB Croatia believes the industry has both responsibility and opportunity to jointly build a professional, transparent, and ethical market.

The document offers theoretical frameworks alongside practical tools for all participants in influencer marketing. Goals include supporting responsible practice, encouraging dialogue, and directing future market development in ways benefiting all stakeholders.

Current regulations in Croatia and the European Union impose special attention and specific arrangements for vulnerable social groups, including communications directed at children, youth, disabled persons, and other vulnerable categories. Special regulations govern inadmissible or restricted forms of marketing communications such as subliminal advertising, comparative and misleading advertising, and unfair business practices.

Individual products and activities face restrictions including tobacco products, medicines, alcohol, and food products with high fat, sugar, and salt content. Forms and models of marketing communication including sales promotion, sponsorship, patronage, product placement, guerrilla marketing, and political communication require adherence to specific standards.

Types of media and creative techniques spanning print media, outdoor advertising, digital media, data usage, and artificial intelligence tools demand specialized considerations. Intellectual property protection remains essential throughout implementations.

The framework emphasizes that guideline compliance alone may not determine whether marketing communications are lawful or ethical. While lawfulness represents an ethical minimum, activities can be lawful yet unethical. The working group recommends comprehensive evaluation of all legal and ethical norms in Croatia and the European Union.

Copyright enforcement in influencer marketing has intensified. Sony Music Entertainment filed a lawsuit in August 2025 against Designer Shoe Warehouse for using copyrighted music in social media posts, including content from paid influencer partnerships that lacked proper disclosure requirements.

Implementation timeline and support

The national campaign accompanying guideline publication encourages ambassador influencers to mark paid collaborations according to standards starting immediately. Posts will carry "#oglas" or "#promo" markers with clear notes about commercial collaborations. Some influencers signed the declaration alongside companies, media, and agencies.

The declaration represents commitment to lawful, decent, honest, and truthful influencer marketing while advocating for guideline promotion and professional principles. Campaign ambassadors demonstrate transparency not as authenticity loss but as respect for audiences and contribution to more ethical digital spaces.

The working group comprises Mario Fraculj from Algebra Bernays University and court expert for marketing, advertising, and market communication; Kristina Gotovac from Communication Laboratory; Nikola Vrdoljak from 404; Kamilo Antolović from Algebra Bernays University and Croatia's first permanent court expert for advertising; Dario Marčac from Crew; and Sandra Babić from Lider Media. Support came from Karla Drašković, Marin Vlainić, and Dunja Ivana Ballon from IAB Croatia.

IAB Croatia holds license ownership through the Croatian Association of Market Communication Societies (HURA), the leading national professional association gathering some of Croatia's most successful agencies from marketing, advertising, public relations, media, digital, and related fields. HURA operates as a separate, independently organized and managed association that forms part of the Interactive Advertising Bureau global network but remains outside ownership, control, or management by Interactive Advertising Bureau, Inc.

For additional questions about guidelines and influencer marketing self-regulation, parties can contact IAB Croatia's Self-Regulation Working Group. While not functioning as a regulatory body that can prosecute violations and impose sanctions, the working group can advise on self-regulatory activities such as creating proprietary guidelines, providing advice on adhering to ethical principles, or sharing best practice examples.

Parties identifying violations of regulation provisions—laws and subordinate acts mentioned in the guidelines—can contact the State Inspectorate or the Agency for Electronic Media. These regulatory bodies issue warnings, binding orders, and reprimands for regulation violations within their domains.

The Media Rating Council issued transparency standards for digital advertising auctions in September 2025, reflecting industry-wide efforts to establish clearer operational standards. The framework addresses auction types, bid conversion processes, reserve pricing, winner determination, and reporting requirements across display, video, audio, search, social, retail media, and connected television channels.

Timeline

• February 19, 2024 - European Commission investigation revealed majority of influencers failed to disclose paid content, prompting enforcement warnings across member states
• July 7, 2024 - TikTok announced enhanced privacy settings and ad transparency controls, including AI-generated content disclosure tools for advertisers
• March 27, 2025 - Major platforms introduced transparency features addressing industry demands for clearer disclosure mechanisms
• September 14, 2025 - European Data Protection Board clarified DSA compliance requirements for digital marketers processing personal data
• November 3, 2025 - IAB Croatia published comprehensive influencer marketing guidelines with national transparency campaign launch
• November 3, 2025 - IAB and IAB Europe released measurement framework for commerce media campaigns, establishing incrementality measurement standards

Summary

Who: IAB Croatia, operating under the Croatian Association of Market Communication Societies (HURA), developed guidelines through a working group comprising industry professionals, academics, media representatives, and civil society members. Partners include the Croatian Association of Digital Publishers (HUDI), European Commission, Croatian Public Relations Association (HUOJ), Solidarna Foundation, and Agency for Electronic Media. The framework affects influencers, brands, marketing agencies, media organizations, and regulatory institutions across Croatia's digital advertising ecosystem.

What: Comprehensive self-regulation guidelines establishing transparency standards for influencer marketing, specifying mandatory disclosure markers, platform-specific implementation protocols, benefit definitions triggering disclosure requirements, and legal-ethical frameworks. The documentation includes 19 pages of detailed guidance with visual examples, flowcharts determining disclosure necessity, and practical implementation instructions across Instagram, Facebook, TikTok, and YouTube platforms. The initiative encompasses a national campaign "Važno je znati kad se plati" promoting guideline adoption and a declaration for voluntary commitment.

When: IAB Croatia published the guidelines on November 3, 2025, launching the transparency campaign simultaneously. Influencer ambassadors began implementing disclosure standards immediately following publication. The framework represents the culmination of months of collaborative development by the working group, building on global self-regulation models while addressing Croatian market specifics and European Union regulatory requirements.

Where: The guidelines apply throughout Croatia's digital marketing ecosystem, covering all platforms where influencers operate including social media networks, blogs, websites, and emerging channels. Geographic scope extends to Croatian-language content and creators operating within Croatian jurisdiction, though principles align with broader European Union consumer protection frameworks and International Chamber of Commerce standards applicable across multiple markets.

Why: IAB Croatia developed the guidelines to address documented transparency failures in influencer marketing, with research showing only 20 percent consumer recognition of commercial content. The initiative responds to growing regulatory scrutiny following European Commission investigations revealing widespread disclosure violations. Self-regulation represents a proactive approach preventing stricter legislative intervention while building trust, protecting consumers—particularly vulnerable groups including children and youth—and establishing Croatia as an example of functional industry self-regulation benefiting all stakeholders.