Following the publication of its recent policy briefing on the UK’s new Data (Use and Access) Act, the APMA is now preparing its formal response to the Information Commissioner’s Office (ICO) consultation on the regulation of online advertising.
This represents a critical opportunity for the affiliate industry to make its voice heard, particularly around the role of attribution.
While the ICO’s “request for views” currently leans heavily towards programmatic advertising, the APMA will be presenting an alternative perspective that reflects the performance-based, consent-led nature of affiliate marketing.
Our goal is to demonstrate that affiliate’s model of value exchange, built on transparency, low data risk, and clear commercial outcomes, should be considered differently within the evolving regulatory framework.
Critical to this perspective is our reliance on attribution cookies to function, rather than more pervasive cookies that build profiles based on personalisation.
The former, we believe, makes our channel distinct from programmatic and display, which tends to be the primary focus of any digital marketing discussions around regulation. Our submission will draw attention to the clear distinction.
Nick Stringer, who is leading the policy work on the APMA’s behalf, noted strong interest from members keen to contribute to the submission. “There is a great willingness to input into an APMA response,” he said. “This is a valuable opportunity to make the case for attribution.”
We’re encouraging members to share their views with us directly.
What do we need from you…?
Read the full list of questions in the ICO request for views. If there are one or more sections you think you can make a strong case for why your business plays a critical part in:
- Helping consumers make better online choices
- Building solutions that consumers actively seek out for whatever reason
- Building data and privacy-conscious digital marketing solutions
- Helping the UK economy to grow in a positive way
then we want to hear from you. Selected contributions may be included in our official response, which is due by 29th August (note we will need your submissions by 15th August). We have created a dedicated form below to collect your submissions.
You can also submit your own response, however, we believe a collective industry view is important. If you’d like more information, read the ICO post in full.
Looking ahead, the APMA is also exploring the idea of hosting a special forum with the ICO later this year, providing a dedicated space for dialogue between the regulator and the affiliate marketing community.
We’ll be sharing more details shortly. In the meantime, members interested in contributing to our response can email us directly or fill in the form below.
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Submit your views for the APMA’s consideration. Deadline: 15th August 2025
