Three ways Welsh and Scottish public body campaigns differ from English ones

What to take away

Three differences matter, and this article names each one: the procurement route the campaign is bought through, the bilingual content duty that applies in Wales, and the disclosure line the public body prescribes. Each is set against English practice, where a creator marketing agency will find notices on Contracts Finder and the Find a Tender Service, and where marketing is often bought through Crown Commercial Service frameworks.

The procurement routes Welsh and Scottish public bodies use

Start with who is actually buying. A Welsh Government campaign may be let by the Welsh Government itself, by a sponsored body such as Natural Resources Wales or the Arts Council of Wales, or by a local authority running its own tender. Each has its own thresholds and its own portal.

Scottish central government buying is steered by Scottish Government procurement policy, published through gov.scot, and delivered by bodies including the Scottish Government's own procurement directorate and the Scottish Exchequer's shared services.

Public sector procurement rules for campaign work sit inside that framework, including the sustainable procurement duty and fair work criteria that suppliers must evidence. You can read the framework at Public sector procurement - gov.scot.

In practice, the route you take depends on value and on whether the work is classed as marketing services, communications consultancy or a creative lot on a national framework. Below is a rough map of what an agency will meet in Wales and Scotland.

Two consequences follow. First, your bid team needs to know which portal the notice appears on before it writes anything. Second, the evaluation questions differ: Scottish tenders commonly ask for fair work practices and environmental management, while Welsh tenders ask for Welsh language provision as a scored criterion rather than a nice extra.

If you have only ever bid in England, the assumptions you carry about thresholds, notices and award transparency will mislead you. The Public Contracts Regulations 2015 set the UK-wide rules for advertising and awarding public contracts, and Welsh and Scottish bodies buy under them too, but the notices appear in different places: Contracts Finder and the Find a Tender Service for UK-wide procurement, Sell2Wales for Welsh public bodies and Public Contracts Scotland for Scottish ones. The wider duties that sit on top of any UK agency are set out in our guide to regulations, codes and platform rules, and they apply here too.

Bilingual content duties for campaigns in Wales

Bilingual content duties in Wales are not a style preference. The Welsh Language (Wales) Measure 2011 and the Welsh Language Standards, introduced on 30 March 2016 and overseen by the Welsh Language Commissioner, put duties on named public bodies, and those duties flow down into contracts those bodies let.

What that means for a creator campaign is concrete. If the client is a body with a Welsh language standards duty, expect the following.

A worked example makes the timing clearer. Suppose a Welsh Government funded health campaign wants six creators, three posting in Welsh and three in English, with a four week window. The English scripts can clear in days.

The Welsh scripts need translation, back translation if the claim is clinical, and an officer's approval. That typically adds a week to ten days before the first post goes live, and it changes the launch date, not the fee.

Treat the Welsh version as a separate deliverable with its own line in the scope, its own approval and its own evidence file. Agencies that fold it into the English fee lose money quietly, and the client notices when the Welsh posts look like afterthoughts.

Scottish Government procurement rules for creator work

Scottish Government procurement rules for creator work follow the same public procurement law as the rest of the UK, but the policy layer is distinct. Across Wales and Scotland, buyers share that law but not the policy. The sustainable procurement duty has been a requirement of public bodies since the Procurement Reform (Scotland) Act 2014 came into force, and the procurement reform programme in Scotland adds duties that English buyers do not impose in the same form.

The headline duties are the sustainable procurement duty, which requires a contracting authority to consider how it can improve economic, social and environmental wellbeing, and fair work practices, which are assessed through selection questions and sometimes through contract conditions.

For a creator campaign, that can mean reporting on how you paid creators, where they are based and what training you provided.

There are practical points that catch agencies out. Thresholds and notices are published on the Public Contracts Scotland portal, not on Contracts Finder or the Find a Tender Service, the portals most English buyers monitor. Some Scottish buyers require a community benefit clause, which can mean offering paid placements or workshops alongside the campaign.

Sub-contracting to individual creators must be declared, and the buyer may ask for evidence of fair terms. Evaluation can score your approach to fair work, so a generic answer scores badly. Award notices and contract spend are published, so your fee structure becomes visible to competitors.

For the policy background, read the Scottish Government's own account of how it buys. The same framework governs campaign and communications suppliers, not just construction or IT. If you want the operating discipline that keeps these bids clean, see our piece on gates for authority, claims.

One more difference matters commercially. Scottish public bodies often buy through collaborative frameworks with named suppliers, so the realistic entry point is a call-off rather than an open tender. Getting onto the framework is the work.

Disclosure expectations on devolved campaigns

Devolved disclosure expectations are stricter in tone than most commercial work, even where the underlying rules are identical across the UK. A government client cannot be seen to hide its hand, so the disclosure line is usually prescribed, not negotiated.

Three rule sets sit underneath. The CAP Code governs non-broadcast advertising, including influencer posts, and requires marketing communications to be obviously identifiable as such. The rules are set out in the Non-broadcast Code - ASA | CAP.

The Competition and Markets Authority expects paid endorsements to be disclosed clearly and up front. Its guidance for creators explains what that looks like in a caption or a video, and it sits at Social media endorsements: guidance for content creators - GOV.UK.

Where a public body runs its own outreach, data protection law also bites. Direct marketing and the public sector are covered by the ICO, which explains consent, soft opt-in and the limits on reusing contact data for promotional messages. That guidance sits at Direct marketing and the public sector | ICO.

In practice, a devolved campaign brief will usually specify:

Agencies that write a generic disclosure line and reuse it across clients will fail a Welsh or Scottish review. Public bodies in Wales and Scotland prescribe the wording because their own reputation is the thing being protected.

Our template for an influencer disclosure policy is a reasonable starting point, but expect the devolved client to amend it.

Where English campaign practice stops applying

Several habits carried over from English campaign work do not survive contact with a devolved buyer in Wales and Scotland.

The first is the assumption that approval is a single sign-off. In Wales, the Welsh language officer is a separate approver with their own timetable. In Scotland, the communications team and the procurement lead may both need to clear the creator list.

The second is the assumption that a framework place is portable. Being on an English marketing framework gives you nothing on a Welsh or Scottish one. You must qualify again, and the questions differ.

The third is the assumption that disclosure is a platform matter. On devolved campaigns it is a governance matter, and the client will want the evidence before the invoice is paid.

The fourth is the assumption that creators can be swapped late. Public bodies often need to know who is speaking on their behalf well before publication, and some will ask for background checks on named individuals. Substituting a creator at short notice can breach the contract, not just annoy the client.

The fifth is pricing. Scottish fair work conditions and Welsh bilingual delivery both add real cost. A fee built from an English day rate for a single-language campaign will be wrong on both counts.

None of this is exotic. It is simply the difference between a buyer whose rules you know and one whose rules you have assumed.

If you are rebuilding your bid approach around a single governance issue rather than a full overhaul, our note on starting from one verified governance problem sets out how to sequence it.

Documenting the differences in one brief

A single brief can carry all of this if you structure it as a comparison rather than a narrative. The aim is that anyone on the account can see, at a glance, which rule applies to which client.

Use a checklist at the top of the brief and complete it before the kick-off call.

Then record the three differences that matter most for this client: route, language, disclosure. One line each, no more.

A worked example of the finished brief might read as follows. Buyer: Scottish agency. Route: call-off from a Scottish framework, fair work scored at selection. Language: English only, no Welsh duty.

Disclosure: client prescribed wording in the first caption line, evidence file with timestamps. Payment: 30 days from acceptance, award notice published. Creator substitution: 10 working days' notice, named individuals fixed.

That is a brief a delivery team can work from without asking the same questions twice. It also survives an audit, which matters more than usual when the client is a public body spending public money.

The wider duty map that sits behind all of this, covering advertising, consumer law and privacy, is worth keeping to hand alongside your bid templates. Our overview of advertising, consumer law, privacy covers the UK-wide layer that devolved rules sit on top of.

Common questions