Building a pre-launch compliance sign-off checklist

The media plan says the TV spot starts on 3 February. Clearcast has version three of the script. The savings line changed on Friday because the pricing team refreshed the comparison basket. The person who owns the renewable-sourcing evidence is on leave until the 28th. Someone now has to say out loud what happens to 3 February.

That decision is what this lesson is about. The rules themselves are settled elsewhere in this module: which body owns what, the fair-treatment duties that shape targeting, the drafting method for a price or savings claim. What follows turns them into an operating sequence with named owners, a fixed order, one evidence pack, and a rule for the launch date when a gate says no.

Why a gate, not a review round

Most teams already "run it past legal". That is a review round, and it fails the same way every time: the reviewer sees an asset, replies in a thread, the asset changes twice more, and six months later nobody can say which version was approved against which evidence.

A gate has four properties a review round lacks. One accountable owner who can say no. A written pass standard, so approval is not taste. A dated record. And teeth on the calendar: a failed gate moves media rather than being talked round by the person holding the launch date.

The teeth matter because the downside is lopsided. Ofgem's penalty powers reachreachThe number of unique people exposed to your message in a given period. Unlike impressions, reach counts each person once, no matter how often they see it.View full definition → up to 10% of a licensee's relevant turnover, and remedies usually arrive with a redress payment on top. Where a campaign strays into regulated financial services, communicating a financial promotion without approval from an FCA-authorised firm is a criminal offence, not a regulatory telling-off. No creative deadline is worth either.

The stage-gate: five checkpoints

Order matters. Gates 1 and 2 close on the claim set and the audience plan, before production money is committed. Gates 3 and 4 close on the asset and the targeting build. Gate 5 closes on the finished file. Running them all in parallel to save a week is exactly how a substantiated claim ends up cleared in a script that was later re-edited.

Gate 1: Claims substantiation

Owner: legal or regulatory affairs, with the pricing, technical or sustainability lead named as evidence provider.

Pass standard: every factual claim has a dated evidence file that pre-dates the claim, built to the drafting method the price-claims lesson sets out, and carrying a version number that matches the asset.

Two things teams miss:

• Expiry. Ofgem has reset the domestic price cap every three months since October 2022. Any saving benchmarked to the cap, or to a competitor tariff that tracks it, has a shelf life measured in weeks. Put an expiry date on each substantiation and diary the cap announcement dates next to the media schedule. Always-on assets are the exposure here: a PPCPPCPay Per Click (PPC) is a digital advertising model where you pay only when a user clicks your ad, not when it is merely displayed.View full definition → ad, an affiliate feed or a poster site has no launch date to protect it, so it needs a recheck date instead.
• Version drift. Evidence approved for "up to £180" attached to an asset that shipped as "up to £200" after a late round is the most common finding in any post-mortem. Sign off the claim string character for character, not the concept.

Fail condition: any claim without a dated file, or with a file whose expiry falls inside the campaign window.

Gate 2: Fair treatment and targeting review

Owner: compliance, co-signed by the operations lead who owns the vulnerability data.

This gate does not re-argue the fair-treatment duties the earlier lesson covers. It tests the campaign against them, and it tests the media brief rather than the artwork, because that is where the damage happens:

• suppression lists (Priority Services Register flags, prepayment meters, accounts in a repayment plan) applied to the seed file but not to the lookalike audiencelookalike audienceAn audience created by ad platforms to target new prospects who resemble your best existing customers, based on shared traits and behaviors.View full definition → built from it
• urgency mechanics on a product where the customer needs time, or a third party's help, to decide
• outboundoutboundProactive outreach that pushes your message to targeted audiences through advertising, email, or direct prospecting, initiated by the seller rather than the buyer.View full definition → calling into a segment with a high nominated-contact rate, where reaching the customer is not the same as reaching the person who decides

Fail condition: the audience build cannot be reproduced from documentation. If nobody can re-run the segment in a year's time, you cannot evidence the exclusion you say you made.

Gate 3: Licence conditions and product routing

Owner: regulatory affairs.

Two checks, and the second is the one that catches people. First, the supply licence conditions on marketing and tariff information: supplier name, the actual cost of the tariff, principal terms presented plainly rather than buried in a footnote.

Second, routing. Does anything in this campaign sit outside the supply licence? Boiler and heating cover, insurance-backed service plans, and credit on a heat pump or solar install can pull the communication into the FCA's financial promotion regime. That changes who may approve it, what the balance of benefit and risk has to look like, and how long the record must be kept, which is longer than most marketing teams keep anything. Copy that Ofgem would wave through can be copy an unauthorised person had no business publishing.

Useful reference: the FTC's guidance on energy marketing and the Telemarketing Sales Rule for US-facing campaigns.

Gate 4: Data and consent

Owner: data protection officer or privacy counsel.

• Lawful basis recorded per audience, not per campaign. "Legitimate interests" written once at the top of a brief covers nothing.
• Smart meter consumption data used for targeting: consent for that use specifically, not consent for billing repurposed.
• Opt-out and unsubscribe tested by a person on the live send infrastructure before go-live, not assumed from the template.
• Automated personalisation or dynamic offer logic: a written explanation of what the model uses and what it excludes.

Fail condition: an untested unsubscribe path. Cheapest gate to pass, most often skipped under deadline.

Gate 5: External clearance and channel format

Owner: media or brand lead, with legal co-sign.

In the UK, TV advertising goes through Clearcast, the body the main commercial broadcasters own and use to clear ads before transmission. Clearcast asks for substantiation, which is why Gate 1 has to be closed first: sending a script forward with the evidence still pending buys you a rejection and a place at the back of the queue. Radio runs the equivalent route through Radiocentre. Plan for one resubmission as the default case, not the exception.

Then the format checks: platform policy on paid social, disclosure on influencer and affiliate placements, legibility of print small print, and any outdoor site that will still be up after the tariff has changed.

Fail condition: airtime booked before clearance is logged.

When a gate fails

Decide the answers before you need them, because in the moment the loudest voice wins:

1. Delay. Real only if the airtime deadlines allow it. TV cancellation deadlines fall weeks ahead of the month of transmission; past that point you pay whether the ad runs or not, so a Gate 5 failure in the final week costs the money and the slot.
2. De-scope. Pull the failing claim, run a pre-cleared fallback. Clearing a brand-only or narrower-claim cut alongside the main version costs little and turns a lost campaign into a lost claim.
3. Accept and document. Only the accountable executive can do this, in writing, with the compliance objection attached to the decision. Marketing does not overrule compliance; it escalates, and the escalation leaves a trace.

Name a deputy for every gate owner while you are at it. A fair share of "we had to go anyway" decisions are annual leave in disguise.

A simple sign-off log structure

A minimal but auditable format, one row per claim or asset:

Campaign: Winter Fixed-Rate Promo 2026
Asset ID: WFR26-TV-30s-v4
Claim: "Save up to £180/year vs. our standard variable tariff"
Substantiation doc: WFR26-calc-v3.xlsx (dated 2026-01-14)
Substantiation expires: 2026-03-31 (next cap period)
Gate 1: J. Alavi, Legal — approved 2026-01-15 (claim string locked)
Gate 2: R. Osei, Compliance — approved 2026-01-16 (PSR + PPM suppressed)
Gate 3: N. Bell, Reg Affairs — approved 2026-01-16; no FCA product in scope
Gate 4: M. Chen, DPO — approved 2026-01-16
Gate 5: Clearcast submitted 2026-01-19, conditions received, v4 resubmitted
Fallback asset: WFR26-TV-30s-BRAND (cleared 2026-01-19)

If a regulator later asks what you knew and when, this log is the answer. If it asks who approved it, the answer is a name and a date, not a mailbox.

🎬 [VIDEO: "How the FTC Regulates Advertising Claims" - youtube.com - search for FTC or Federal Trade Commission explainer videos on advertising substantiation requirements, a clear primer on the legal standard behind Gate 1]

Key Takeaways

• Sign-off is a gate, not a review round: one accountable owner, a written pass standard, a dated record, and a consequence for the launch date.
• Close claims and targeting gates before production spend; close external clearance last, on the finished file, with a resubmission cycle assumed.
• Substantiation expires. Benchmark a saving to the price cap and you have inherited its quarterly reset, which bites hardest on always-on and affiliate assets.
• Check product routing every time: cover plans and install finance can move a communication into the FCA financial promotion regime, where an unauthorised approval is a criminal matter.
• Pre-clear a fallback cut. It converts a failed gate from a lost slot into a narrower claim, and it removes the pressure to overrule compliance.