# The pre-launch compliance sweep every campaign must pass
Three days before launch, the marketing director of a mid-size European hotel chain got a call from legal: the influencer partnership video had no #ad disclosure, the booking page failed a basic screen-reader test, and nobody could locate signed consent records for the guest email list used in the retargetingretargetingShowing ads to users who have previously visited your site or interacted with your brand, to bring them back and drive conversion.Voir la définition complète → campaign. Launch was delayed nine days. The fix cost more than the compliance review would have.
This is the scene every campaign should be designed to avoid. Below is a stage-gate checklist, the kind that should sit between "creative approved" and "campaign live," walked through using a realistic hotel-chain launch: a three-country summer promotion for a fictional composite chain we'll call "Aurelia Hotels," running paid social, email, and an influencer partnership across Germany, Spain, and the UK.
A stage-gate simply means the campaign cannot pass to the next phase until every gate item is signed off. No exceptions, no "we'll fix it post-launch."
The rule. The General Data Protection Regulation (GDPR), enforced by national data protection authorities across the EU/EEA and by the UK's Information Commissioner's Office (ICO) post-Brexit under UK GDPR, governs how hotels collect, store, and use guest personal data for marketing.
What trips up hotel campaigns specifically. Guest data arrives from multiple sources: booking engines, property management systems (PMS), loyalty programs, Wi-Fi login forms, spa reservations. Each source may have collected consent under different terms, or none at all.
Aurelia's retargetingretargetingShowing ads to users who have previously visited your site or interacted with your brand, to bring them back and drive conversion.Voir la définition complète → list mixed loyalty members (opted in for marketing) with guests who booked once through a third-party OTA (online travel agency, e.g., Booking.com or Expedia) and never consented to Aurelia's direct marketing at all. That second group cannot legally receive Aurelia's promotional email.
Gate checklist:
A useful primer on lawful bases: ICO's guide to lawful basis for processing.
The rule. In the EU, the European Accessibility Act (EAA), which became applicable from June 2025, requires digital services including travel and hospitality booking platforms to meet accessibility standards for people with disabilities. In the US, the Americans with Disabilities Act (ADA) has been interpreted by courts to apply to websites, and hotel booking pages are a frequent litigation target. The common technical benchmark referenced across both regimes is the Web Content Accessibility Guidelines (WCAG), currently version 2.2.
What trips up hotel campaigns specifically. Marketing teams often build landing pages fast, outside the core booking engine, for a specific promotion. These pages get skipped in accessibility QA because "the real booking page is already compliant."
Aurelia's summer promo used a standalone landing pagelanding pageA standalone web page built for a single campaign goal, designed to maximise conversions by removing distractions and focusing visitors on one action.Voir la définition complète → with a countdown timer (flashing, no pause control) and a room-selector carousel with no keyboard navigation. Both fail basic WCAG 2.2 checks.
Gate checklist:
Free testing resource: WebAIM's WAVE tool lets you scan any live URL for accessibility violations in seconds.
The rule. In the UK, the Advertising Standards Authority (ASA) and Competition and Markets Authority (CMA) require clear, upfront disclosure (#ad, "paid partnership") when influencers are compensated, including with free stays. In the US, the Federal Trade Commission (FTC) has near-identical requirements under its endorsement guidelines. In the EU, the Unfair Commercial Practices Directive underpins similar national rules, enforced by bodies like Germany's Wettbewerbszentrale.
What trips up hotel campaigns specifically. Hotels routinely host influencers for free, sometimes with no direct payment beyond the comped stay. Many brands wrongly assume disclosure is only required when cash changes hands. It is not. A free stay, discount, or gifted product with an expectation of coverage triggers disclosure rules in the UK, US, and most EU markets.
Aurelia's influencer received a complimentary three-night stay and posted a glowing reel with no disclosure at all, believing "gifted, not paid" was exempt.
Gate checklist:
The ASA's influencer guidance is a solid reference: ASA/CAP guidance on influencer ad disclosure.
🎬 [VIDEO: "FTC Endorsement Guides Explained" - youtube.com/results?search_query=FTC+endorsement+guides+influencer+disclosure - search for current FTC or consumer-protection explainer videos on influencer marketing disclosure rules, useful for grounding the US comparison]
Vérification des acquis
1. What is the defining feature of a stage-gate compliance process in campaign launches?
2. Why did Aurelia Hotels' guest email list create a GDPR compliance problem for the retargeting campaign?
3. A hotel wants to use guest data collected from a Wi-Fi login form for a promotional campaign. What does the lesson's framing imply is the correct approach?
4. Select ALL correct answers about why the Aurelia Hotels launch delay occurred.
Sélectionnez toutes les réponses correctes.
5. Select ALL correct answers about which regulatory bodies are relevant to a campaign like Aurelia's, which runs in Germany, Spain, and the UK.
Sélectionnez toutes les réponses correctes.
The rule. Consumer protection law (in the EU, the Unfair Commercial Practices Directive and Consumer Rights Directive; in the UK, the Consumer Rights Act 2015 and CMA enforcement; in the US, FTC Act Section 5 on unfair or deceptive practices) requires that promotional terms be clear, not misleading, and genuinely honored.
What trips up hotel campaigns specifically. "Free night" and "up to 40% off" promotions are high-risk phrasing. Regulators scrutinize blackout dates, room-category exclusions, and whether the advertised price was ever genuinely available.
Aurelia's ad said "rooms from €89," but that rate applied to a single room type at one property on weekdays only, information disclosed only three clicks deep. This is the kind of drip pricing and reference-price issue regulators have actively pursued against travel companies, including EU-wide "Booking.com-style" enforcement actions on price transparency in recent years.
Gate checklist:
Aurelia's ad: "Rooms from €89/night."
Actual available rate for that price: 1 room type, 1 property, Monday to Thursday only, city tax (€3/night) and resort fee (€12/night) excluded.
All-in real minimum price a consumer could pay: €89 + €3 + €12 = €104/night.
Gap between advertised and all-in price: €15, or roughly 17% higher than advertised. That gap is exactly what triggers regulator complaints and consumer group scrutiny. The fix is not to remove the promotion, it's to state the all-in price or clearly flag "excludes taxes and fees, shown at checkout" directly next to the headline figure.