Spain's influencer law: what to label and what to keep
Spain's influencer law, developed through Royal Decree 444/2024, requires clear labeling of any advertising content and, if you cross certain income and audience thresholds, registration as a "user of special relevance" with the CNMC, Spain's media regulator. It doesn't matter whether you earn a little or a lot: if you create commercial content on social media in Spain, you're already subject to the General Advertising Law, which requires clearly identifying any paid collaboration. Here's who must comply with each obligation, and what documentation you should keep to avoid an unpleasant surprise.
Who must register as a "user of special relevance"?
Royal Decree 444/2024 only requires registration in Spain's State Registry of Audiovisual Communication Service Providers if you meet several requirements at the same time: gross income of at least €300,000 a year from your activity, at least one million followers on a single video platform (or two million combined across platforms), and a minimum of 24 videos published in the last year. If you don't reach those figures, you're not a "user of special relevance" — but that doesn't free you from the rest of the obligations.
Ad labeling applies to everyone, not just the big names
This is the nuance many creators miss: the obligation to label advertising doesn't depend on your follower count. Any creator who gets paid or receives products in exchange for posting must clearly indicate when content is advertising, identify who they're collaborating with, and label reposts, stories and mentions too — not just the original post. If you use AI-generated voices or images in sponsored content, you must disclose that explicitly. The CNMC can act even if you don't reach the registration thresholds, if it detects misleading advertising, hidden collaborations, or content aimed at minors without the required safeguards.
What to keep as proof of each collaboration
The regulation explicitly requires keeping contracts and proof of campaigns — which in practice means having, for each collaboration: the contract or agreement with the brand, the campaign brief you received, screenshots or links of the published content, and the corresponding invoice. The more brands you manage at once, the easier it is to lose track of something — and that's exactly what the CNMC reviews if it opens an investigation. Keeping this centralized in one tool, instead of scattered across WhatsApp, email and a spreadsheet, is the difference between resolving a query in five minutes or spending an entire afternoon hunting for paperwork.
Fines if you don't comply
Penalties for those who fall into the "user of special relevance" category can reach up to €1.5 million in the most serious cases. For other creators, while fines under the General Advertising Law are smaller, exposure has grown: the EU's Digital Services Act requires large platforms to publish records of the ads shown, including the advertiser's identity, making it much easier to spot poorly labeled sponsored content.
How to prepare without overcomplicating things
You don't need a legal department to comply. Centralizing your collaboration contracts, briefs, campaign tasks and invoicing in one place already covers most of the record-keeping the regulation asks for. That's exactly what Influx solves for instagrammers and agencies: campaigns, tasks, income and invoices in one place, ready to check whenever you need them.
Frequently asked questions
What is Spain's influencer law? It's the popular name for Royal Decree 444/2024, which develops Spain's General Audiovisual Communication Law and regulates content creators with relevant income and audience as "users of special relevance," subjecting them to obligations similar to traditional broadcasters.
Do micro and nano influencers need to label collaborations even below those thresholds? Yes. The obligation to identify advertising comes from the General Advertising Law and applies to any creator who receives payment or products in exchange for content, regardless of audience size.
What happens if I label sponsored content incorrectly? You could face penalties that, for users of special relevance, reach up to €1.5 million in serious cases; for other creators, fines depend on advertising and unfair competition law, but they're just as real.
What documents should I keep as proof of a brand collaboration? At minimum: the contract or agreement, the campaign brief, screenshots or links of the published content, and the invoice issued. Keeping these organized by campaign protects you in case of any review.