NO CLEAR DEFINITION OF ‘ADVERTISEMENT’ The absence of a proper definition for “advertisement” can open avenues for politicians to misuse government funds, said Bengaluru-based advocate Rahul

Machaiah. “These guidelines will lead to a proliferation of government ads which may seem like innocuous communication, but indirectly shape personality cults. It will blur the lines

between government and political parties or leaders. There should be a definition so that the policy isn’t misused for personal PR and image-building of politicians,” he said. Machaiah

referred to the Supreme Court’s observations in the Common Cause vs Union of India case, which cautioned against using government ads for personal or political gain. He pointed out that the

an independent Ombudsman for regulating government ads. Although the SC did not accept this, it is high time we have such an ombudsman to regulate the content of government advertisements

and expenditure. Otherwise, the government which enjoys huge economic power will ensure that the digital space which is akin to a ‘marketplace of ideas’ gets distorted and flooded with

favourable content,” Rahul said. The state’s new digital advertisement guidelines only say that digital advertising is any advertising content — text, image, audio, video, audio-visual

creative, photographs, etc — that is disseminated through digital platforms or digital devices connected to the internet. The format of these digital ads include long and short videos,

banners, pop-ups, audio, images, and others. In the case of advertisements placed by private entities — which are covered by the Advertising Standards Council of India (ASCI), a

self-regulatory body — the public can file _complaints_ against objectionable television ads that violate Sections 6 and 7 of the Cable Television Networks (Regulation) Act 1995. But the

state’s guidelines for digital advertising do not mention any such mechanism for digital advertising or influencers. The guidelines applicable to government print and television

advertisements come under the _Karnataka Jaahiratu Neeti_ (Karnataka Advertising Policy) 2013,_ _which defines an advertisement as “all forms of briefed classified advertisements and

attractive advertisements of the government.” DIPR Commissioner Hemant M Nimbalkar told TNM that these digital ad guidelines were also an extension of the existing _Jaahiratu Neeti_. 

Besides, the state government has currently appointed _two Congress party office-bearers_, Ramesh Babu and Ramachandrappa, to oversee the Information Department’s Media Advertising Review

Committee. This has not gone down well with the Opposition Bharatiya Janata Party (BJP). THE ALLURE OF THE ‘INFLUENCER’ Speaking to TNM, Commissioner Nimbalkar said that the DIPR’s decision

to engage influencers is strategically aimed at broadening outreach. “We want to reach people and raise awareness about the government’s initiatives through a medium they are accustomed to.

The younger generation gravitates towards watching reels and following influencers; what better way to connect with them than through the platforms they already engage with on social media?”

he asked. India, in particular, has become a global hub for influencers. The country boasts the world’s largest YouTube subscriber base, with 462 million active users on the platform. India

is home to approximately 2.5 to 3.5 million content creators, of whom around 1,50,000 monetise their content. The influencer marketing industry in India is thriving, with a compound annual

growth rate (CAGR) of 30%. According to influencer marketing firm Kofluence, the number of creators who can monetise their content is expected to grow by 15-20% in the coming years. The

allure of influencer advertising lies in its ability to bypass traditional marketing channels and forge direct connections with specific demographics. Social media personalities who boast

millions of followers wield considerable sway — particularly over younger audiences.  Elaborating on the process for engaging digital media entities, the Commissioner said, “The department

will provide a brief to these entities, and the content should be created based on that guidance. We don’t actively approach advertisers or influencers; instead, they can come to us. Our

empanelment will be based on established eligibility criteria.” After empanelment, influencers must submit their content drafts to the DIPR for review. The department will assess whether the

content aligns with the provided brief before it can be published. He added that the influencers must also disclose when their content is sponsored or part of a paid collaboration with the

government. The guidelines, however, don't explicitly state this. CRITERIA: FOLLOWER COUNT The criteria for social media influencers have been categorised into three tiers based on the

number of followers they have: nano (1 lakh to 5 lakh followers), micro (5 lakh to 10 lakh followers), and macro (above 10 lakh followers) influencers. However, while this criteria mirrors

the policy for placing ads in newspapers and television channels on the basis of circulation and viewership, this logic can backfire when applied to influencers, according to Bengaluru-based

advocate Vinay Sreenivasa. “Right-wing influencers typically have larger audiences, which contradicts the idea of balance,” he said, adding that Rajasthan’s Congress government introduced

something similar before the assembly elections in 2023, followed by Uttar Pradesh in 2024 which has a BJP government. “It makes you wonder — what’s really different? Ultimately, this comes

down to the health of our democracy, and many political parties fall short in safeguarding it.” Vinay said. Bengaluru-based activist and journalist Shivasundar also pointed out the dangers

of relying on an influencer’s follower count. “If follower count is the only criterion, it could lead to a biassed selection process favouring certain ideologies, particularly right-wing

influencers.”  A research paper titled __Influencer collaboration on YouTube: Changing political outreach in the 2024 Indian elections_ _noted that the BJP “clearly has a massive advantage

over other parties” with some social media influencers, “but the spread of influencers in various languages is broad, and these influencers are mostly relevant for national level politics,

for the kinds of politicians who have a broad, cross-regional profile.” It also stated that several digital influencers had conducted more interviews with national politicians during the

period of the study than most political journalists. Commissioner Nimbalkar, however, said that follower count is not the sole criterion for selecting influencers. According to him, the DIPR

will also examine the type of content that influencers have been publishing. “For example, if the government wants to promote a health scheme for women, we would look to enrol a

gynaecologist who has been actively creating social media content to raise awareness on women’s health issues.”  “Our focus is on the IEC (Information, Education, and Communication) method,

which aims to use influencers not just for their reach but for their subject expertise and ability to communicate meaningful, targeted messages,” the Commissioner added. WHERE LIES THE

ACCOUNTABILITY Activists have expressed concerns about this policy for several reasons — including the lack of supervision compared to traditional media, the potential blurring of lines

between advertising and independent content, and the substantial impact influencers can have on public perception and opinion.  Vinay Sreenivasa pointed out that while government ads in

newspapers are subject to regulations and laws, there’s no such framework for influencers. “Social media influencers paid by the government are likely to reflect the state’s positions in

their content. The power of influencers is growing — some have millions of followers — and if they start promoting problematic content, it can have a huge impact,” he said.  He further

argued that influencers need accountability mechanisms similar to media bodies like the News Broadcasters and Digital Association. “It’s unwise for any government, state or union, to work

with influencers without clear guidelines.” Vinay also raised concerns about the possibility that the government can misuse influencers to control the narrative. “The current state

government sees the strong influence of right-wing voices on social media and wants to counterbalance it by controlling the narrative. But this raises serious democratic concerns. What does

it mean for democracy when everyone is trying to shape public opinion? These questions aren’t being discussed enough in our society.” “What worries me is the inconsistency — an influencer

can say one thing today and something entirely different tomorrow, affecting public opinion. Influencers hold significant sway over people, so it’s crucial for governments, including the

Karnataka government, to clarify their approach. At the same time, influencers themselves need to reflect on their role and responsibilities. And as social media users, we also need to ask:

Do we want influencers to operate without any accountability or guidelines?” The presence of influencers in government campaigns also compromises the authenticity of public opinion,

Shivasundar said. “I have a fundamental issue with ‘influencing’ in this context. People should be informed, not influenced. The government’s role should be to educate citizens about

available programs, allowing them to make independent decisions. Using influencers would turn this into a marketing exercise rather than a public service,” he said. Besides, the government

already has the option to advertise on various platforms, and it could also find inspiration in the Bengaluru police’s approach. _As the first police force to establish a social media

presence in India,_ they have quite effectively been raising awareness and sharing important updates such as traffic restrictions via the internet. With 1.4 million followers on Twitter,

3,60,000 on Instagram, and 7,37,000 on Facebook, they engage with a broad audience through relatable content like reels, photos, and memes. Their social media team is responsive, often

engaging with users regarding law and order issues, showcasing a proactive commitment to community interaction. MONEY MATTERS Activists have also raised concerns about the lack of

transparency, especially with regard to the links between revenue and content. “With newspapers or TV channels, at least we can track their revenue and taxes. But how do we know what

influencers are earning or where their money is coming from? Someone like Beer Biceps, for example—how much does he make, and from what sources? There’s a lack of transparency,” Vinay said.

The weight of this concern has already been evident in the way the Union government has gone about employing influencers. In July 2023, _Congress MP Manish Tewari_ asked a question in the

Lok Sabha about the Union government’s use of social media influencers. He asked for a list of empanelled influencers who were given ads by the Union government. However, the Minister for

Information and Broadcasting Anurag Thakur did not provide details of influencers and only mentioned that four agencies had been empanelled. This means that the public has no idea which

individuals are disseminating information or viewpoints pushed by the Union government.  It is to be noted that the digital ad guidelines in Karnataka state that the pricing structure for

influencer campaigns will be as per the prices specified by the Directorate of Advertising and Visual Publicity (DAVP). So, following the DAVP’s rate guidelines for similar categories,

independent pricing can be determined on a case-by-case basis in instances where prices are dynamic. KARNATAKA ISN’T THE FIRST The Karnataka government’s venture into digital advertising is

part of a broader shift in politics, both domestically and globally, towards the use of influencer marketing. In 2023, Union Minister Piyush Goyal had met with YouTubers in Delhi as part of

a government outreach effort. Influencers were contacted via email and social media, flown to the national capital, and provided with accommodation for the meeting. The then Congress-led

Rajasthan government had also adopted a similar model, categorising social media influencers based on follower counts and tying payments to reach and engagement metrics. For example,

Rajasthan verifies that an influencer's post reaches at least 5% of their followers before payments are released. The content must also adhere to strict guidelines, prohibiting anything

deemed “indecent, obscene, or anti-national.” The Aam Aadmi Party in Punjab also came up with the ‘Punjab Influencer Empowerment Policy, 2023. “Along with positive outreach, it also aims to

contribute to the collective fight against fake and manipulated news,” the official statement read.  Recently, the Uttar Pradesh government announced a similar social media policy but with

even stricter regulations. Influencers in UP are divided into four categories based on their follower counts, with specific payment limits set for each platform: On platforms like X

(formerly Twitter), Facebook, and Instagram, monthly payments range from Rs 2 lakh to Rs 5 lakh. On YouTube, the payment limits for videos, shorts, and podcasts can go as high as Rs 8 lakh.

  Uttar Pradesh has also introduced strict regulations governing the content of influencers' posts. The state authorities can withhold payments if content is found to “showcase the

government’s schemes in an incorrect manner or with ill intent,” or if it “hurts the sentiments of different sections of society.” Additionally, the policy mandates legal action against

influencers or digital platforms that post content deemed “anti-national, anti-social, or derogatory.”