KOL Ad Disclosure Rules in Hong Kong: #ad, Paid Partnership Labels and the Law
Hong Kong has no KOL-specific law. The Trade Descriptions Ordinance applies: up to a HK$500,000 fine and 5 years' jail. Platform labels and #ad wording inside.
Hong Kong has no law written specifically for KOLs or influencers. KOL promotion falls mainly under the Trade Descriptions Ordinance (Cap. 362): applying a false or misleading trade description in the course of trade is a criminal offence, with a maximum penalty of a HK$500,000 fine and 5 years' imprisonment. The law doesn't say you must write #ad, but every platform requires commercial collaborations to switch on the "Paid partnership" label.
Updated October 2026 · general information, not legal advice · reviewed every quarter.
What actually applies in Hong Kong
| Rule | What it covers | What it means for KOLs |
|---|---|---|
| Trade Descriptions Ordinance (Cap. 362) | Bans false or misleading trade descriptions, and unfair trade practices such as misleading omissions | When a KOL promotes a brand, what they say about ingredients, effects and prices is regulated |
| Misrepresentation Ordinance (Cap. 284) | Losses can be claimed where a contract was entered into because of a misrepresentation | Consumers can use it to claim against traders |
| Undesirable Medical Advertisements Ordinance (Cap. 231) | Restricts medical claims about certain diseases and physical conditions | KOL content on health supplements, medical aesthetics and skincare needs extra care |
| Platform policies | Meta, TikTok and YouTube branded content policies | Require the paid partnership label to be switched on; content that breaks them can be removed |
Key points:
- The Trade Descriptions Ordinance is enforced by the Customs and Excise Department, which can investigate and prosecute.
- Any form of description counts. A false or misleading trade description is illegal whether it appears in an advertisement or on any online platform.
- Company management can be personally liable. If an offence was committed with the consent or connivance of a director or manager, or was caused by their neglect, they can be prosecuted personally.
- Not saying it's a collaboration may be misleading. The law doesn't expressly require #ad, but whether hiding a commercial relationship counts as a "misleading omission" depends on the case. The safest approach is to disclose clearly.
Disclosure tools on each platform
| Platform | Tool | What viewers see |
|---|---|---|
| Branded content tools, tagging the brand partner | "Paid partnership" at the top of the post | |
| Branded content tools | "Paid partnership" | |
| Threads | Depends on whether the account has branded content tools | Without the tool, state the collaboration at the start of the text |
| TikTok | Content disclosure setting, with "Branded content" turned on | "Paid partnership" label |
| YouTube | Tick "Includes paid promotion" when uploading | "Includes paid promotion" shown at the start of the video |
| Xiaohongshu | Partnership notes made through the Pugongying (蒲公英) platform | Partnership label; commercial notes made outside the platform may break community rules |
Platform interfaces change, so check the latest settings in the app before you post.
Brand compliance checklist
- The contract says the KOL must switch on the platform's paid partnership label and disclose at the start of the caption.
- Barter (product-for-post) deals, free experiences and affiliate links need disclosure too.
- The brief lists which claims about the product's effects may and may not be made, with supporting evidence attached.
- Don't ask the KOL to hide the collaboration, or to write only positive reviews.
- Prices, offers and deadlines match the official information.
- Medical, health and medical aesthetics products are reviewed by legal or compliance staff first.
- Keep the brief, drafts and approval records.
- Keep the collaboration label when the brand reposts the content or runs it as an ad.
For how to word the contract clauses, see the Hong Kong KOL contract checklist.
Disclosure wording in Chinese and English
| Situation | Chinese | English |
|---|---|---|
| Paid partnership | 【廣告】 ("ad"), #合作 ("collaboration"), #品牌合作 ("brand collaboration") | #ad, #sponsored, Paid partnership with @brand |
| Barter | 產品由 @品牌 提供 ("product provided by @brand"), #合作 | Gifted by @brand #gifted |
| Affiliate link | 經此連結購買，我會獲得佣金 ("I earn a commission if you buy through this link") | I earn a commission from this link #affiliate |
| Brand ambassador | #品牌大使 ("brand ambassador") @品牌 | #ambassador @brand |
Tips:
- Put it first. The disclosure should be visible before "more", not buried at the end of a string of hashtags.
- Use words your audience understands. #sp and #collab aren't clear enough, so avoid them.
- Say it in videos. In Reels, TikTok and YouTube videos, state the collaboration at the start, aloud or in subtitles.
FAQ
Do Hong Kong KOLs have to write #ad on sponsored posts?
Hong Kong law doesn't expressly require #ad, but platform policies require the paid partnership label to be switched on, and hiding a commercial relationship may also be misleading. Disclose clearly every time.
Is there a law regulating KOLs in Hong Kong?
There's no specific law. The Trade Descriptions Ordinance mainly applies, and the Misrepresentation Ordinance and the Undesirable Medical Advertisements Ordinance may also apply.
What happens if a KOL makes a misleading claim?
Breaching the Trade Descriptions Ordinance is a criminal offence, with a maximum penalty of a HK$500,000 fine and 5 years' imprisonment. The brand's directors or managers may also be personally liable.
Do barter collaborations need disclosure?
Yes. Receiving free products or services is also a commercial relationship, so write "product provided by the brand" (產品由品牌提供) or #gifted.
How do I turn on Instagram's paid partnership label?
When you post, turn on the branded content option in the advanced settings, then tag the brand's account. The brand account needs to approve the partner.
Is the brand responsible for a KOL's posts?
The brand is responsible for the product information it supplies and the claims it asks the KOL to make. The contract should say the KOL may only use claims the brand has supplied and verified.
Back to the 2026 Hong Kong KOL agency guide.