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Rules and ethics

Part of 7 referral programme mistakes UK startups should avoid

7 referral programme mistakes UK startups should avoid

Seven referral programme mistakes UK startups make, from vague reward terms to undeclared tracking, with the ICO, company law and advertising rules that catch them.

7 referral programme mistakes UK startups should avoid

Use the first failed check below as your stopping point: fix that part of the referral programme, then work through the remaining branches before inviting more participants. A clean result on one check does not prove that the rest of the setup is ready.

Decision checklist

  • Does the promotion match the actual offer and its conditions?
  • Can customers find the eligibility rules, reward limit and expiry?
  • Are referral tracking and privacy information clear?
  • Is there a set response to suspected abuse?
  • Can the company record reward costs and assess results beyond sign-ups?

Seven mistakes and first fixes

  • Terms only in founder's headpublish eligibility
  • No lawful basisrecord before configuration
  • Rewards from personal fundsuse company records
  • Tax left to year endagree treatment early
  • Ads overpromisematch claims to conditions
  • No fraud reversalwrite reversal rule
  • Only sign-ups measuredtrack to repeat purchase

If the headline promises more than the offer

Change the customer-facing claim before publishing if it promises a reward more broadly than the programme's actual conditions allow. For example, do not suggest that every friend earns a reward when the rules limit each referrer to one.

Put important limits beside the offer, rather than requiring customers to search elsewhere for them. Check the finished wording against the conditions and the advertising rules. If a claim is too broad, correct it before publishing or boosting the promotion again.

  • Rule of thumb: Make the reward claim match the conditions customers can see.

If customers cannot confirm the conditions

Publish clear eligibility conditions before asking customers to share a referral link. State what counts as a new customer, the maximum rewards a referrer can earn and when a reward expires. Keep the terms accessible even if a participant later closes an account.

Save dated copies of the wording so you can identify which conditions applied if a payment is questioned. Compare the published terms with the actual eligibility and payout process, and ensure the disclosure policy reflects the expiry date customers are shown.

Written referral conditions

  • Who counts as a new customer
  • How many rewards one referrer can earn
  • When a reward expires
  • Publish where customers can still reach it
  • Rule of thumb: If the conditions are hard to find, pause promotion.

If referral activity is being tracked

Treat referral codes and link activity as personal data processing, not as automatically anonymous measurement. Before tracking begins, record the lawful basis and explain the purpose in the privacy information. Do not collect referral data first and attempt to justify the method afterwards.

Check the setup against GDPR-compliant referral tracking, especially when codes, cookies or consent are involved. Keep to the data protection principles and maintain concise processing records showing the method and purpose. The ICO's personal information guidance is another reference point.

  • Rule of thumb: Decide and record the basis before tracking starts.

If the privacy information says nothing about referrals

Update a notice that explains orders and newsletters but leaves out referral activity. Tell customers that referral codes are used, what the referred customer is told and how long link data is kept. Describe the actual purpose instead of relying on wording about unrelated uses of customer information.

Compare the privacy information with the live process whenever the handling of codes or link data changes. If they no longer match, revise the wording or the process and keep a dated copy of each version. Check the data protection advice as part of that review.

  • Rule of thumb: If referral data is used, explain it in the notice.

If the response to abuse is still undecided

Decide how to handle self-referrals, duplicate accounts and recycled codes before issuing the first reward. Set out whether reversed credit will be removed or repaid, and who will tell the referrer. Do not invent a new response only after a suspected case appears.

Keep dated records of reversals, including what changed and when, and apply the stated process consistently. Make the relevant condition available before customers take part. Use the risk scenarios to help check for gaps in the response before increasing promotion or paying further rewards.

  • Rule of thumb: Publish the reversal process before the first abuse case.

If registrations rise but value is unclear

Do not increase spend on registrations alone. Check how many referred customers place a second order, and calculate what each customer costs to acquire. Define both measures consistently before using results to decide whether the programme is working.

Use the same definitions over time instead of treating sign-ups as the final outcome. Review common measurement mistakes and compare your target with sector-level ROI. This keeps the decision grounded in later purchases and acquisition cost, not just the initial response.

  • Rule of thumb: Measure beyond sign-ups before scaling.

If reward payments sit outside company records

Route rewards through the company rather than paying informally from a founder's personal account. Keep programme costs visible in the company's accounting records so they can be checked later. The official company records guidance can help when reviewing that record trail.

Include budget assumptions, account for unclaimed rewards, and agree the tax treatment with an accountant. Informal personal payments can obscure the programme's actual cost and leave an accounting gap.

  • Rule of thumb: Company-funded rewards need a company-record trail.

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