Regulators in the United Kingdom, the United States, Canada, New Zealand and Australia, the five jurisdictions covered here, can name the advertiser when they announce the outcome of a case about its marketing, and a business in any of them can also be required to issue a notice about its own case.
A marketing claim can be accurate and still breach the rules if the business does not hold the evidence for it. This piece sets out which claims need evidence in five jurisdictions and by when, and how a marketing team can identify claims that lack it while the copy is still in draft.
The SEC’s September 2026 Risk Alert sets out issues examiners observed regarding adviser annual compliance reviews, including how advisers documented them.
Governor Gavin Newsom signed California Senate Bill 1050 (SB 1050) into law on 16 September 2026, and from 1 January 2027 it requires a disclosure when an advertisement prominently includes a realistic AI-generated performer who is not recognisable as a real, identifiable person.
The European Union prohibits several kinds of environmental claims outright from 27 September 2026. The United States, United Kingdom, Australia, New Zealand and Canada each use a different instrument, and in all six the evidence supporting a green claim is expected to exist when the claim is made.
Four marketing claims, each compliant in the market it was written for, tested across lending, insurance, healthcare and real estate in six jurisdictions. No approval applied beyond its own market, and in healthcare, the format itself was lawful in some countries and prohibited in others.
The EU has no single marketing regulator, and its rules take effect by date, not by instrument. A walk through the 2026 calendar, the AI Act's Article 50, the Empowering Consumers Directive, the Digital Fairness Act and the pending Green Claims Directive, plus the sectoral rules that carry no date.
Employee advocacy is sold to marketing as amplification. The scripted origin that triggers the regulatory obligations is the same design that delivers the reach, so the reach and the exposure come together.
The fourth Marketing Rule Risk Alert covers whether disclosure is present and prominent, and whether the firm can show why it believed the content complied.
When an advertiser claims a level of proof it cannot support, the claim itself is the violation, whatever the disclosures say. What the FTC substantiation standard requires before you publish, and why pointing to a study is not the same as holding the evidence.
Hidden ads and undisclosed reviews now breach four regulators' rules: ASA, CMA, FCA and FTC. What health marketers must disclose before they publish.
California's AI Transparency Act (SB 942) is operative from 2 August 2026. It settles AI-content provenance, not whether that content is compliant.