At the beginning of last month, something interesting happened. That’s not to say that interesting things only happen to me occasionally, because they don’t, but this particular interesting thing stuck out and made my day.

What was it?

Someone I bumped into at an industry event just after a panel discussion on social media influencers, emailed me a copy of the new National Media Council Advertising Guide. Since then I’ve been wondering why we haven’t heard more about this document yet, which should have Zomato “blaggers” and self-styled social media influencers quaking in their boots.

Before I go into further details, it’s time for my usual courtesy disclaimer: I have written a lot about social media influencers and I do (really!) value the role they play in our digital media marketing eco-system. Provided, that is, they know what they are doing, know who their audiences are, can write decent copy, and – the most recent addition to my list – are fully licensed. The latter is not only a legal requirement in the UAE now, but also helps to separate the wheat from the chaff. If you want to know what I’m talking about, do read my June 2018 column, aptly titled, “It’s time to talk about influencers. Again.”

Here’s the thing. Since the influencer licensing requirements became law, we’ve been waiting for the next logical step – disclosure guidelines. Being a licensed influencer is one thing, but having to clearly label your social media posts as 'advert' or 'paid' or similar is quite another. Personally, I strongly believe that readers and viewers should be made aware of where and how a piece of content has come from. It means that they can make up their own minds whether to trust it or not. I can look at a post by any of the many excellent licensed influencers, bloggers, and content generators in our industry, and say, “Yup, I like it and I don’t mind that they got the meal for free or were paid a fee for the post. I know that generating good content takes time and effort and I understand that influencers, just like me, don’t work for free.” I could also look at a post of yet another mindless McDonald’s 'review' on Instagram or the latest glowing KFC 'review' on Zomato by so called “Instagram bloggers” and I could say “Listen here, you blithering moron, I don’t care if it’s a signature collection burger or a whatever zinger – it’s all plastic food. In other words: I can be all adult about things.

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Back to the new National Media Council Advertising Guide, though. Yes, it covers social media advertising. Yes, advertising is defined very broadly as posting content on behalf of someone else and being paid for it or receiving payment in kind, i.e. a free meal or a free hotel stay. Oh, and yes, it covers UAE-based influencers and influencers from abroad working on your company’s behalf here. It also specifies that “clear language” should be used when disclosing paid partnerships, which means that burying a little #ad hashtag among 34 other hashtags won’t do. By the way, did you notice how a certain type of “influencers” and “blaggers” always uses tons of hashtags, most of which are unrelated to the image or content they post? Well, there you go.

The NMC guidelines also specify that disclosure should be made at the beginning of a piece of content, not at the end, that the disclosure statement can’t be hidden behind a “Read more” link or on another page, and that – in the case of video or audio content – the disclosure is made verbally in the video/audio as well as in the text accompanying the video/audio content.

There are many more requirements contained in the NMC document, but perhaps the most interesting of all of them is who the council intends to hold responsible in case of any breaches of the guidelines. Clearly, there are only two options: The influencer or the company engaging the influencer. The council went with the second option, which means it’s your responsibility to only engage licensed influencers and insist on full and NMC-compliant disclosure or face a fine of AED5,000 for the first offense, which rises to AED20,000 for repeat offenses. The NMC also has the power to delete posts/content that does not meet the guidelines or shut down pages/platforms/websites that do not comply.

Perhaps, then, all the self-styled blaggers and influencers aren’t quaking in their boots just yet, because the potential penalties aren’t aimed at them, but wait. None of us likes fines. Not DTCM fines, not traffic fines, not National Media Council fines. If we can avoid fines, we will, and so I predict that, before too long, the swamp is going to dry out and we’ll be left with influencers and content generators that are worth their salt and know what they’re doing.

Guess what? We’ll all be better off for it!

About the Author: Martin Kubler is the founder of Iconsulthotels and the CEO of sps:affinity. Iconsulthotels is now sps:hotels — a leading hotel management consultancy that provides its clients forward-looking business strategies, keeping them ahead of the market. Email: