Creator Portfolio Due Diligence

Creator Marketing Has a
Due Diligence Problem.

Signal Intelligence helps enterprise brand-side teams close that gap through creator portfolio due diligence, documented assessment and monthly portfolio monitoring.

A follower count. A recent feed scroll. A gut feel. That is not a process — and when it goes wrong, the board wants to know what you did to prevent it.

Our Purpose
We audit creator portfolios.
We identify risk.
We monitor changes.
We tell you before it becomes your problem.
The Problem

The due diligence gap in creator marketing.

Creator marketing developed faster than the governance structures surrounding it.

Most organisations apply formal due diligence to their suppliers, their directors, and their business partners. They conduct financial checks, reputational searches, and compliance reviews before entering material relationships.

They do not apply equivalent scrutiny to creators who represent their brands to audiences of millions. The gap is not intentional — it reflects the speed at which creator marketing has grown relative to the governance frameworks that should surround it.

The risk is rarely visible in a creator's recent feed. It lives in their personal history, their business relationships, their regulatory compliance record, and the narratives forming around them in corners of the internet nobody thought to check.

When it goes wrong, the question from legal, from the board, and from the press is always the same: what did you do to prevent this?

Signal Intelligence gives you a documented, sourced, and auditable answer to that question. Before you need it.

Regulatory Landscape

Every major market now
has active enforcement.

Select a market to see the specific regulatory framework your brand faces.

EU AI Act · Digital Services Act · UCPD · Digital Fairness Act (forthcoming)
EU-wide — The overarching framework. Fully in force 2026.
27 markets. One framework. Local enforcement.
The risk for brands

The EU AI Act requires all AI-generated content in commercial contexts to be clearly labelled — not buried behind a Read More button, not left to platform detection. The standard is whether a reasonable audience member would understand the content's origin. Platform labels have been confirmed by the Commission as insufficient for compliance purposes.

Under the UCPD, influencers are now classified as traders across all 27 member states. Brands share liability for the commercial content their creators produce. The Digital Fairness Act — consultation closed October 2025 with strong support — is expected to introduce mandatory creator registration, minimum disclosure standards, and platform verification obligations.

Signal Intelligence checks
  • EU AI Act synthetic creator detection — is this creator human?
  • AI content labelling compliance assessment for existing partnerships
  • UCPD trader classification review — brand co-liability exposure
  • DSA cross-platform disclosure consistency audit
  • Digital Fairness Act readiness mapping
27 markets One EU-wide framework creates simultaneous exposure across every member state. A single non-compliant campaign can trigger enforcement in multiple jurisdictions.
Loi n°2023-451 (French Influencer Act) · ARPP AI Monitoring · Joint liability
France — AI enforcement at scale. Brand-level actions from H2 2025.
Active brand-level enforcement. Max fine €300,000.
The risk for brands

France's ARPP reviewed 194,000 pieces of content in H1 2025 alone — a 222% increase year-on-year. Speech-to-text analysis is now operational: verbal brand mentions in video content are detectable as non-compliant. In H2 2025 the ARPP shifted enforcement focus from creators to brands. If your creator has been identified as a repeat non-complier, you are now an enforcement target.

Brand liability is joint and several with the creator under French law. The maximum fine under the French Influencer Act is €300,000. The Loi Ferragni additionally regulates charitable marketing transparency.

Signal Intelligence checks
  • ARPP compliance history — has your creator been identified?
  • Speech-to-text exposure audit — verbal brand mentions in video
  • Disclosure placement review — French standard requires prominent labelling
  • Charitable marketing transparency check under Loi Ferragni
  • Joint liability exposure mapping for brand
194,000 Posts reviewed by ARPP in H1 2025 alone. If your creator programme is active in France, the probability of content review is no longer theoretical.
UWG §5a(4) · HWG (Medicines Advertising Act) · Private enforcement
Germany — Competitor brands can bring enforcement cases against you.
High enforcement risk. No regulator needed.
The risk for brands

Germany's primary enforcement mechanism for influencer non-compliance is not a regulator — it is your competitors. Under UWG §5a(4), competitor brands can bring private enforcement cases against you for your creator's disclosure failures, without involving any regulatory authority. This happens routinely in the German market. A disclosure failure is simultaneously a compliance gap and a commercial vulnerability that a direct competitor can exploit.

Health brands face dual exposure under the HWG. Any health claim in sponsored content — even a mild one — must be clinically substantiated.

Signal Intelligence checks
  • UWG §5a(4) disclosure compliance review
  • Hashtag-cloud and "See More" placement audit — ruled insufficient by German courts
  • HWG health claim analysis for wellness and beauty creators
  • Competitor conflict screening — who else has this creator worked with
  • Private enforcement exposure assessment
Competitor risk In Germany, your disclosure failures are your competitors' legal resource. Private enforcement cases are now routine. No regulator needed to bring action against your brand.
AGCOM Code of Conduct · Ferragni Law · AGCM · Criminal precedent
Italy — Three concurrent regulatory frameworks. Criminal prosecution precedent set.
Most comprehensively regulated market in Europe. Max fine €600,000.
The risk for brands

Italy has the most comprehensive creator regulatory architecture in Europe. The AGCOM Code of Conduct applies to creators with 500,000 or more followers on any single platform, or 1 million average monthly views. These creators are regulated as broadcast media entities. The maximum AGCOM fine is €600,000 — the highest creator-specific regulatory fine in Europe. Brand partners share compliance responsibility alongside the creator.

The Ferragni Law regulates charitable marketing transparency. The Ferragni criminal case established precedent that misleading creator marketing can constitute aggravated fraud under Italian criminal law.

Signal Intelligence checks
  • AGCOM threshold check — does this creator trigger broadcast-level regulation?
  • AGCOM registration status verification
  • AGCM enforcement history search for creator and category
  • Charitable marketing transparency review under the Ferragni Law
  • Criminal precedent risk assessment
€600,000 Maximum AGCOM fine — the highest creator-specific regulatory penalty in Europe. Italy's three-layer framework is fully operational.
Circular 1/2020 (CNMC) · Spanish Civil Code · UCPD implementation
Spain — CNMC framework active. Brands co-liable for creator disclosures.
Active regulatory framework. Enforcement accelerating.
The risk for brands

Spain's CNMC has published regulatory guidance clarifying disclosure requirements for commercial content. The framework covers both macro and micro-influencers — reach threshold does not determine whether disclosure is required, only whether the content was produced for commercial purposes. Brands commissioning content without ensuring disclosure compliance carry co-liability under the UCPD framework as implemented in Spain.

Signal Intelligence checks
  • CNMC disclosure compliance review
  • Commercial content identification — gifted vs paid vs organic
  • Brand co-liability assessment under UCPD
  • Historical compliance record for creator in Spanish market
  • Cross-market consistency check for brands running EU-wide campaigns
UCPD aligned Spain's framework aligns with EU-wide UCPD trader classification. Brand liability exposure applies regardless of creator reach.
ACM (Authority for Consumers & Markets) · Dutch Consumer Protection Act
Netherlands — ACM among Europe's most active enforcement bodies.
Active enforcement. Formal investigations and fines issued.
The risk for brands

The Netherlands' ACM has issued formal enforcement actions and fines against both creators and brands for influencer marketing non-compliance. The ACM's enforcement approach includes proactive market sweeps, not just complaint-driven actions. Dutch law requires all commercial content to be immediately and unambiguously identifiable as such — without the audience needing to seek that information.

Signal Intelligence checks
  • ACM enforcement history for creator and category
  • Dutch disclosure standard compliance review — immediate and unambiguous
  • Proactive sweep risk assessment
  • Brand co-liability mapping
  • Cross-border campaign consistency — Netherlands within EU-wide framework
Proactive sweeps ACM does not wait for complaints. Active market monitoring means non-compliant content is found, not reported.
Belgian Economic Law Code · JEP (Jury of Ethical Practices in Advertising)
Belgium — Dual enforcement: regulatory and self-regulatory.
Active. Dual enforcement track creates multiplied exposure.
The risk for brands

Belgium operates dual enforcement: the JEP as a self-regulatory body and formal regulatory enforcement under the Belgian Economic Law Code. Non-compliance can trigger both tracks simultaneously. Belgian disclosure requirements apply to all commercial content regardless of platform or creator size.

Signal Intelligence checks
  • JEP enforcement history search
  • Belgian Economic Law Code disclosure compliance review
  • Dual-track exposure mapping
  • Brand co-liability assessment
  • Cross-language consistency — Flemish and French-speaking markets
Dual track Self-regulatory and statutory enforcement both active. Non-compliant content can trigger formal proceedings and JEP action simultaneously.
UOKiK · UOKIK Consumer Protection Act · 10% global turnover penalty
Poland — UOKiK enforcement at cartel-level penalties.
10% global turnover ceiling. Brands directly in scope.
The risk for brands

Poland's UOKiK has issued guidance specifically addressing influencer marketing disclosure obligations and has taken enforcement action against brands — not just creators — for non-compliance. The maximum fine under UOKiK's consumer protection framework is 10% of global turnover. This is a cartel-level penalty applied to influencer marketing disclosure failures.

Signal Intelligence checks
  • UOKiK enforcement history for creator and category
  • Polish disclosure standard compliance review
  • Brand-direct liability exposure assessment
  • Contractual disclosure requirement adequacy review
  • 10% turnover ceiling risk quantification
10% turnover Maximum fine — equivalent to cartel enforcement. Brands, not just creators, are primary enforcement targets in Poland.
Marketing Control Act · Consumer Authority (Forbrukerrådet)
Norway — Among Europe's most active enforcement bodies.
Active enforcement. Financial penalties issued.
The risk for brands

Norway's Consumer Authority is widely regarded as one of the most proactive influencer marketing enforcement bodies in Europe. Financial penalties for disclosure failures have been issued to both creators and brands. The Marketing Control Act requires all sponsored content to be clearly labelled. Brands running Scandinavian campaigns often treat Norway as a proxy for regional compliance risk.

Signal Intelligence checks
  • Marketing Control Act disclosure compliance review
  • Consumer Authority enforcement history for creator and category
  • Labelling adequacy assessment — Norwegian standard is among Europe's strictest
  • Brand co-liability exposure review
  • Cross-Nordic compliance consistency check
Most active Norway's Consumer Authority is among Europe's most proactive influencer marketing enforcers. Penalties have been issued to brands directly.
ASA CAP Code · DMCCA 2024 · FCA COMC · CMA
UK — Three parallel enforcement regimes. Named non-compliers list active.
Multiple parallel enforcement. Brand-level accountability confirmed.
The risk for brands

The UK operates three parallel enforcement regimes for influencer marketing. The ASA enforces disclosure compliance and maintains a named non-compliers list — creators on that list have been identified, monitored, warned, and still failed to comply. The DMCCA 2024 significantly strengthened CMA and Trading Standards enforcement powers; the CMA 10% global turnover penalty ceiling applies. The FCA's financial promotions rules apply strictly to any financial services content.

ASA targeted sanctions are escalating: advertising restrictions — preventing named creators from using advertising agencies and media buying services — are now available as a formal sanction.

Signal Intelligence checks
  • ASA named non-compliers list check — mandatory before every UK activation
  • CAP Code disclosure compliance — placement and prominence audit
  • CMA unfair commercial practices screening under DMCCA
  • FCA financial promotion compliance for fintech and investment brands
  • FCA finfluencer register check where applicable
10% turnover CMA penalty ceiling under DMCCA 2024. ASA-CMA referral protocol confirmed — the self-regulatory and statutory enforcement tracks are now formally connected.
FTC Endorsement Guides · Consumer Reviews Rule · FINRA · SEC · Class action
USA — Dual liability standard established. Class action wave building.
Enforcement up 340% since 2021. Brands as primary respondents.
The risk for brands

FTC enforcement actions in the influencer marketing category are up 340% since 2021. The Consumer Reviews and Testimonials Rule explicitly prohibits fake social media indicators. The dual liability standard is firmly established — brands are primary respondents alongside creators in FTC enforcement actions. FINRA and the SEC both actively enforce against financial services creator content.

A class action wave is building across the US creator economy in the authenticity misrepresentation category. Brands that activated creators specifically for their personal narrative — and where that narrative proves materially false — face indirect but real litigation exposure.

Signal Intelligence checks
  • FTC enforcement history search for creator and brand category
  • Authenticity claim verification — is the narrative this creator was activated for still demonstrably true?
  • Fake metric screening — follower, engagement, and view authenticity
  • FINRA/SEC compliance check for financial services creators
  • Class action exposure mapping — prior consumer-facing claims
340% Increase in FTC enforcement actions since 2021. Dual liability means the brand is a primary respondent — not a secondary one — in FTC actions.
Legal intelligence — published 24 May 2026

“The legal system is gradually aligning the responsibilities of digital content creators with the harms their influence can cause.” — Antonis Glykis & Christina Avgousti, Elias Neocleous & Co LLC, Cyprus Mail

Research

The Signal Papers

Long-form thought leadership on creator governance, risk intelligence, and regulatory strategy for enterprise brand-side teams.

THE SIGNAL INTELLIGENCE BRIEFING
Creator Governance: What We've Learned So Far
A consolidated view of the most significant developments in creator risk, regulatory change, and brand governance since January 2024.
PDF ↓
SIGNAL PAPERS — No. 01
Most Organisations Apply More Due Diligence to a Supplier Than a Creator Representing Their Brand to Millions of Consumers
Influencer Marketing Has a Due Diligence Gap
PDF ↓
SIGNAL PAPERS — No. 02
Brands Spend Years Building Their Reputation. Creators Can Borrow It For A Month.
Creators Borrow Brands. Lenders Do Checks.
PDF ↓
SIGNAL PAPERS — No. 03
A Marketing Executive May Spend Years Earning The Right To Speak For A Brand. A Creator Can Be Given The Same Responsibility In A Week.
Employees Earn The Right To Represent A Brand. Creators Are Often Granted It.
PDF ↓
SIGNAL PAPERS — No. 04
The Risks In Your Creator Programme Are Probably Already Visible.
Creator Governance Does Not Create Risk. It Makes Existing Risk Visible.
PDF ↓
SIGNAL PAPERS — No. 05
Content Drift ⟹ Portfolio Drift
Constant Change Is Here To Stay
PDF ↓
SIGNAL PAPERS — No. 06
The Creator Governance Maturity Framework
Where Are You on the Journey from Ad Hoc to Governed?
PDF ↓
SIGNAL PAPERS — No. 07
The Assessment Gap
Why Basic Creator Checks Are No Longer Enough
PDF ↓
SIGNAL PAPERS — No. 08
The Monitoring Gap
Approval Is A Point In Time. Monitoring Is A Process.
PDF ↓
SIGNAL PAPERS — No. 09
The Ownership Gap
When Everyone Owns Part Of The Process, Nobody Owns The Risk.
PDF ↓
SIGNAL PAPERS — No. 10
The Creator Governance Operating Model
From Creator Marketing To Creator Governance.
PDF ↓
The Signal — Newsletter Archive

Industry observations on Creator Risk, regulatory change and Creator Governance.

Methodology

Audit. Monitor. Assess. Escalate.

A four-stage framework covering creator portfolios from initial due diligence through ongoing monitoring and individual assessment.

01 — AUDIT
Portfolio Audit
Audit
Portfolio-level due diligence at scale. Every creator in your programme assessed against a consistent framework. The starting point for any governed creator programme.
02 — TRACK
Portfolio Monitoring
Monitor
Monthly review of approved creator portfolios. TRACK identifies material changes in conduct, content, alignment or regulatory exposure after approval.
03 — TRACE
Creator Due Diligence
Assess
Deep-dive creator due diligence for individuals requiring additional review. TRACE assessments examine Trajectory, Reputation, Alignment, Content and Exposure.
04 — REACT
Priority Watch
Escalate
Priority monitoring for your highest-value creator relationships. Direct analyst escalation when material developments emerge. For partnerships where being second to know is not an option.

Audit your creator portfolio. Complimentary.

Upload up to 100 creators and we will return a portfolio-level governance triage: Green, Amber, Red or Priority Review, with sourced summary notes where visible risk signals are identified.

Complimentary up to 100 creators. Larger enterprise portfolios can be reviewed by arrangement.

What the Portfolio Audit includes

  • Portfolio-level governance triage for every creator
  • Identity, handle and platform-link review
  • Visible public-record and profile risk signals
  • Sourced summary notes on flagged creators
  • Priority list of creators requiring TRACE assessment
  • Governance gaps and recommended next steps
Email Your Creator Portfolio →

Send your creator list to contact@signalintelligence.consulting

Preferred format: Creator Handle and Platform. Additional fields welcome but not required. Download template →

Portfolio submissions are treated as confidential. If your organisation requires a mutual NDA before submission, please contact us before uploading.

Free up to 100 creators. Enterprise portfolios above 100 — contact us directly. Turnaround typically 5–7 business days.

About

Independent analytical
intelligence for brand-side teams.

Signal Intelligence is an independent creator risk intelligence firm. We exist to provide the managed analytical service layer that the creator marketing industry has never had — combining proprietary data methodology with human analytical judgement to produce intelligence that platforms and agencies cannot.

Our clients are enterprise brand-side communications, marketing, legal, and compliance teams. The organisations that understand creator marketing carries material risk — and that managing it requires more than a platform dashboard or an agency’s brand safety checkbox.

We are not a platform. We do not sell licences or seats. We produce intelligence — documented, sourced, and auditable — that gives brand teams a defensible answer when the risk materialises and someone asks what due diligence was done.

Why Signal Intelligence
Independent by design.

Simplified portfolio level risk management with human analytical output. Signal Intelligence is not an influencer agency, talent agency or campaign platform. Our role is to assess, document and monitor creator risk from the brand's perspective.

Regulatory intelligence built in

The Signal, The Signal Papers and the regulatory landscape provide a standing intelligence layer for brand-side teams operating across multiple markets.

Signal Above the Noise

Creator portfolios generate a constant stream of activity. Most changes are routine. A small number have the potential to become regulatory issues, reputational issues or governance issues. Signal Intelligence helps organisations recognise those developments before they become a problem.

Escalate when it matters

Priority monitoring for your highest-value and highest-risk creator relationships. Creator monitoring with direct analyst escalation when material risk signals emerge. For partnerships where being second to know is not an option.

Contact

Talk to us about your
creator programme.

Tell us what you have and what you need. We will come back within one business day — no platform pitch, no lengthy onboarding.

⏱️
Response time
Within one business day
📍
Based in
London, United Kingdom
Send us a message