A working draft: disclosure standards for paid recommendation

Regulatory disclosure rules describe what must be said. They say very little about what must be kept. In practice that means most disclosures are unverifiable after the fact.

This draft proposes three retention obligations: the commercial terms of the arrangement, the evidence supporting any performance claim, and the version of the creative that ran.

We are applying the draft internally first. Portfolio companies are expected to comply before we ask anyone else to, and we will publish what breaks.