Do you need to label advertising according to the law

Yes, in most jurisdictions — and especially in Russia since September 2022 — advertising in Telegram channels must be labeled according to the law. Russia's Federal Law "On Advertising" (No. 38-FZ), amended to cover internet advertising, requires that all online ads carry a special "Advertisement" (Реклама) label, include advertiser information, and be registered through an Operator of Advertising Data (ORD). Failure to comply can result in fines ranging from ₽30,000 to ₽500,000 for individuals and channel owners, and up to ₽700,000 for legal entities.

Understanding Advertising Labeling Requirements

The legal landscape around advertising disclosure in messaging platforms has changed dramatically. While the specifics vary by country, the general trend worldwide is toward greater transparency in digital advertising. The European Union's Digital Services Act (DSA), the US Federal Trade Commission (FTC) guidelines, and Russia's amendments to the advertising law all share a common goal: ensuring audiences can clearly distinguish paid content from organic posts.

What Counts as Advertising?

Not every mention of a product or service qualifies as advertising under the law. Here is how regulators typically define it:

  • Paid promotion — any post for which you received money, goods, services, or other compensation
  • Affiliate content — posts containing affiliate links where you earn commission
  • Cross-promotion for payment — promoting another channel or group in exchange for compensation
  • Sponsored content — posts where an advertiser influenced the content, even partially
  • Self-promotion of commercial services — advertising your own paid products or courses

Important: Organic recommendations without any compensation, personal opinions about products you purchased yourself, and news coverage of companies generally do not require advertising labels — but the line can be blurry.

What Does NOT Require Labeling?

  • Your own channel's organic content and announcements
  • Social or charitable announcements (PSAs) with no commercial benefit
  • Mutual cross-promotion without payment (in some jurisdictions)
  • Editorial mentions where no compensation was exchanged
  • Sharing your genuine personal experience with a product (no affiliate link, no payment)

How the Russian Advertising Law Works for Telegram Channels

Since Russia represents one of the largest Telegram user bases, the September 2022 amendments to Federal Law No. 38-FZ deserve special attention. The system works through a chain of responsibilities.

Step 1: Register with an ORD

Before publishing any advertisement, you must register with an Operator of Advertising Data (ORD). These are organizations authorized by Roskomnadzor to collect and store advertising data. Currently approved ORDs include platforms like Yandex OFD, VK ORD, Ozon ORD, and others.

  • Create an account on an ORD platform
  • Provide your personal or business details (INN, OGRNIP, or company registration data)
  • Set up your advertising inventory (your Telegram channel)

Step 2: Create an Advertising Contract Record

For each advertising deal, you must register a contract in the ORD system:

  • Upload or describe the agreement between you and the advertiser
  • Specify the parties involved (advertiser, intermediary if applicable, and publisher)
  • Record the financial terms (amount, currency, payment method)

Step 3: Obtain an Advertising Token (Erid)

Each individual advertisement must receive a unique identifier called an erid (a creative token). This token is generated by the ORD and must be included in the advertisement itself.

  • Submit the creative (ad text, images, links) to the ORD
  • Receive an erid token (format: LjN8KxxxYYY)
  • Include this token visibly in the published post

Step 4: Publish with Proper Labels

Your Telegram post must include:

  1. The word "Реклама" (Advertisement) — clearly visible
  2. The erid token — typically at the beginning or end of the post
  3. Advertiser information — the legal name and INN (taxpayer ID) of the advertiser

A properly labeled ad post might look like this:

erid: LjN8K2bR7

🔥 Try the new SuperApp for managing your finances!
Download now: [link]

Реклама. ООО "СуперАпп", ИНН 7712345678

Step 5: Submit Post-Campaign Reports

After the advertisement has been published, you must submit statistical reports to the ORD within 30 days:

  • Number of views/impressions
  • Dates of publication
  • Actual reach data
  • Confirmation that the ad was displayed as registered

Penalties for Non-Compliance

The consequences of ignoring advertising labeling requirements are real and increasingly enforced.

Violation Fine for Individuals Fine for Legal Entities Missing "Реклама" label ₽30,000 – ₽100,000 ₽200,000 – ₽500,000 Missing erid token ₽30,000 – ₽100,000 ₽200,000 – ₽500,000 Failure to report to ORD ₽10,000 – ₽30,000 ₽100,000 – ₽300,000 Missing advertiser data ₽20,000 – ₽200,000 ₽100,000 – ₽700,000

Enforcement has ramped up significantly since mid-2023, with Roskomnadzor actively monitoring popular channels and processing complaints.

International Advertising Disclosure Rules

If your channel targets an international audience or you operate outside Russia, other regulations may apply.

United States (FTC Guidelines)

The FTC requires clear and conspicuous disclosure of material connections between endorsers and brands. Common compliant labels include:

  • #ad or #sponsored placed prominently (not buried in hashtags)
  • "Paid partnership with [Brand]"
  • "This post is sponsored by [Brand]"

European Union (DSA & National Laws)

EU member states require advertising to be clearly identifiable as such. The Digital Services Act adds platform-level requirements, but content creators must:

  • Use labels like "Advertisement" or "Sponsored"
  • Identify the entity on whose behalf the ad is displayed
  • Not use deceptive formats that disguise ads as organic content

Other Jurisdictions

Countries like the UK (ASA guidelines), Australia (ACCC), and Canada (Competition Bureau) have similar transparency requirements. The universal principle: if you were paid, say so.

Tips & Best Practices

  • Create templates: Build a reusable ad post template with all required fields (erid placeholder, "Реклама" label, advertiser details block) so you never forget an element
  • Use ORD integrations: Some ORD platforms offer Telegram bots or browser extensions that streamline token generation — use them to save time
  • Negotiate labeling responsibility upfront: Clarify in your advertising contract who is responsible for obtaining the erid and submitting reports — the channel owner, the advertiser, or the intermediary agency
  • Keep records of all agreements: Even for small deals and barter arrangements, document the terms in writing and save them for at least one year
  • Separate ad posts from editorial: Consider using a consistent visual format for ads (e.g., a specific emoji or separator) so your audience recognizes sponsored content immediately — this builds trust
  • Leverage platforms like tgchannel.space: When your channel content is mirrored on the web via services like tgchannel.space, ensure that advertising labels are preserved in the web version, as web content is also subject to advertising regulations
  • Track regulatory updates: Advertising laws are evolving rapidly — subscribe to legal news channels or follow your ORD's updates to stay compliant

Common Mistakes

Mistake 1: Assuming small channels are exempt
Why it's wrong: The law applies to all advertising regardless of channel size. A channel with 500 subscribers is subject to the same rules as one with 500,000.
How to avoid: Label every paid post properly, regardless of your audience size.

Mistake 2: Hiding the "Реклама" label in tiny text or behind a "show more" fold
Why it's wrong: The label must be clearly visible to the reader without extra actions. Regulators specifically look for attempts to obscure disclosure.
How to avoid: Place the label at the top or bottom of the post in regular text size.

Mistake 3: Using a single erid for multiple different advertisements
Why it's wrong: Each unique creative (ad text + visuals combination) requires its own erid token. Reusing tokens across different ads violates reporting requirements.
How to avoid: Generate a new erid for each distinct advertisement through your ORD.

Mistake 4: Not labeling barter deals
Why it's wrong: If you received any form of compensation — including free products, mutual promotion agreements with commercial entities, or service access — it counts as advertising.
How to avoid: Treat any post where you received value in exchange for coverage as an advertisement.

Mistake 5: Forgetting to submit post-campaign reports
Why it's wrong: Registration alone is not enough. The law requires statistical reports after the ad runs. Missing the 30-day reporting window triggers separate penalties.
How to avoid: Set calendar reminders for report submission deadlines after each ad campaign.

Frequently Asked Questions

Do I need to label advertising if my channel has fewer than 1,000 subscribers?
Yes. Russian advertising law does not set a minimum subscriber threshold. Any paid advertising content must be labeled regardless of your channel's size. The same principle applies in most other jurisdictions — disclosure requirements are based on the nature of the content, not the size of the audience.

What about native advertising or "soft" integrations?
Native advertising — where the promotion is woven naturally into editorial content — still requires labeling. If an advertiser compensated you to mention their product, even in a conversational tone, it must carry the "Реклама" label and erid token. The format of the ad does not change the legal requirement.

Can the advertiser handle all the labeling and reporting for me?
Yes, this is possible and common. The advertising contract can specify that the advertiser or their agency is responsible for ORD registration, erid generation, and report submission. However, as the channel owner (publisher), you share responsibility — if the advertiser fails to comply, regulators may still hold you accountable.

Are cross-promotions with other Telegram channels considered advertising?
It depends on whether compensation is involved. Free mutual cross-promotions between non-commercial channels generally do not require labeling. However, if money changes hands, or if one party is a commercial entity promoting its services, the post should be labeled as advertising.

Do these rules apply to pinned messages or channel descriptions?
Yes. Any advertising content, regardless of its format or placement within the channel — regular posts, pinned messages, or even channel descriptions — must comply with labeling requirements if it constitutes paid promotion.