Scottish and Welsh retail media, devolved rules and bilingual campaigns

What to take away

• Scottish Welsh retail media devolved regulation is not one rulebook: planning consent, bilingual duties and equality law come from different bodies.
• Scottish planning policy is set nationally, yet signage permission still runs through the local planning authority.
• Welsh language expectations are strongest in public-facing creative, and the Welsh Language Commissioner is the body to watch.
• The Equality Act 2010 applies across Britain, so bilingual targeting still needs an objective justification.
• The CAP Code is UK-wide, so the ASA applies the same standards to Welsh and English creative.
• Scottish Government statistics are the first place to check for regional planning data.

What devolution means for advertising regulation in Scotland and Wales

Advertising content rules are reserved. The CAP Code applies across the United Kingdom, so the ASA handles complaints about a Scottish or Welsh retail media placement in the same way it handles an English one.

What differs is everything around the creative: planning consent for physical signage, language duties for public bodies, and equality law that bites when a campaign treats groups differently.

Across Scotland and Wales, the Scottish Government runs devolved policy on planning, and its own pages set out that remit About the Scottish Government - gov.scot. For retail media planners, that means a digital placement in Glasgow or Cardiff can sit under one advertising code while the surrounding signage, language and public-sector rules change with the border.

The named devolved bodies matter here. The Welsh Language Commissioner promotes and facilitates Welsh language use. The Scottish Government sets planning policy through gov.scot. Local planning authorities in both nations decide individual applications. None of these bodies approves ad copy, but each can stop a campaign that ignores its remit.

Retail media teams used to booking national campaigns often assume a single compliance pass covers the whole of Britain. It does not. A sponsored placement shown to shoppers in Wrexham and a bus-side panel in Dundee may share a creative file but not a rulebook.

Scottish planning and signage rules from gov.scot

Scottish planning policy for signage comes from the Scottish Government, which publishes its planning position on gov.scot Planning and architecture - gov.scot. The policy framework is national, but decisions on advert consent rest with the local planning authority covering the site.

Retail media often includes physical formats: in-store screens, trolley panels, car park six-sheets and click-and-collect signage. In Scotland, these can need advertisement consent separate from any building consent. A screen inside a shop usually sits outside planning control, while an illuminated panel facing a street often does not.

The practical test is visibility and permanence. A temporary promotional banner may fall under deemed consent rules. A permanent digital screen on a store facade is more likely to need an application. Planners should check the local development plan and any conservation area or listed building designation before booking.

Scotland also has its own permitted development rights, which differ from England. A format that needs no application in Manchester may need one in Aberdeen. That gap is one reason a single UK-wide signage spec can fail north of the border.

For the wider booking picture on sponsored placements, see our guide to advertising rules in England, which covers the checks that apply before a placement is confirmed.

Bilingual creative requirements and Welsh language expectations

Welsh bilingual creative requirements are the clearest divergence in the United Kingdom. The Welsh Language (Wales) Measure 2011 and the standards made under it place duties on public bodies and some other organisations to treat Welsh no less favourably than English.

Those standards do not bind every retailer. A private retailer with no public funding generally escapes them. But the expectation still shapes campaigns, because public bodies, transport operators and many publicly funded partners will ask for bilingual assets as a condition of a placement.

The Welsh Language Commissioner is the named body here. It can investigate complaints and issue guidance. For retail media in Wales, the risk is not a fine on the ad itself, but a lost placement or a public relations problem when a campaign appears in English only in a Welsh-speaking area.

Good bilingual retail media campaigns do more than translate. Welsh copy often runs longer than English, so a headline that fits a 6-second bumper in English may not fit in Welsh. Designers should set the Welsh version first and let the English adapt, not the reverse.

Language choice also affects targeting. A campaign shown to shoppers in Gwynedd, Anglesey or Ceredigion reaches a different language profile from one shown in Cardiff or Newport. Treating Wales as one market wastes budget and can look careless to the audience.

Equality Act 2010 duties in regional and bilingual campaigns

The Equality Act 2010 applies across Great Britain and sets out protected characteristics including race, religion or belief, sex and age Equality Act 2010. It does not ban targeting by nation or language, but it does mean a campaign cannot exclude a group without an objective reason.

Language targeting is usually lawful because it reflects a genuine audience difference. Targeting Welsh speakers in Wales is not discrimination. Excluding Welsh speakers from a public-facing campaign, or serving them a poorer version, is the riskier pattern.

Regional campaigns can also raise indirect discrimination questions when a rule or practice puts one group at a disadvantage. A campaign that requires an English-only app to claim an offer, in an area where Welsh is the everyday language for many shoppers, is the kind of design a compliance team should question.

Equality duties also touch data. Retail media targeting relies on personal data, so UK GDPR and the Data Protection Act 2018 apply alongside the Equality Act. The Information Commissioner's Office is the regulator to consult on lawful targeting and profiling.

For a fuller map of the authorities involved, our guide to rules and compliance sets out the five kinds of authority a launch must satisfy.

ASA and CAP Code application to bilingual retail media creative

The CAP Code is the rulebook the ASA applies to non-broadcast advertising, including retail media Advertising codes - ASA | CAP. It is UK-wide, so a Welsh-language ad is judged on the same principles as an English one: it must be legal, decent, honest and truthful.

ASA bilingual creative raises two practical points. First, the meaning must match. If the Welsh headline promises something the English small print does not, the ad can mislead. Second, qualifications must be clear in the language the consumer is reading.

Retail media adds a third point: the ad must be identifiable as an ad. Sponsored placements, shoppable tiles and retailer media panels all need clear labelling, whatever the language. A bilingual campaign does not get more latitude on that.

Complaints can arrive in either language, and the ASA handles Welsh-language complaints. Planners in Scotland and Wales should keep a record of the English and Welsh versions side by side, with the date each was approved, so a challenge can be answered quickly.

The CMA also has a role in pricing and promotional claims, particularly around reference prices and urgency messaging. A bilingual countdown or a 'was/now' claim must be accurate in both languages.

Scottish Government statistics for regional campaign planning

Scottish Government statistics are published through its statistics and research hub Statistics and research - gov.scot. They cover population, households, deprivation, transport and local authority profiles, all of which feed regional campaign planning.

For retail media, the useful datasets are the ones that break Scotland into council areas. Population and household estimates let planners size an audience. Deprivation measures help decide where a value-led message will land better than a premium one.

Welsh equivalents come from the Office for National Statistics and from Welsh Government statistics. The ONS is the UK-wide source for population and census data, and it publishes nation-level breakdowns that planners can use alongside Scottish figures.

Use the data to challenge assumptions. Scotland is not a single market: the Highlands, the central belt and the north east differ in density, income and travel patterns. A campaign built on Greater Glasgow numbers will misjudge Inverness.

Keep a note of the reference date on any dataset you cite in a media plan. Devolved statistics are revised, and a plan that quotes an old figure can be challenged by a client or a regulator.

Compliance checks before a bilingual retail media launch

Work through these steps in order. Each one closes a gap that a national campaign would not have.

1. Confirm which nation each placement sits in, and whether any site needs advertisement consent.
2. Check whether the client or partner is a public body subject to Welsh language standards.
3. Decide which assets will run in Welsh, and set the Welsh copy first in the design.
4. Review targeting for equality risk, and record the objective reason for any group excluded.
5. Match every claim in both languages, including small print and urgency messaging.
6. Log approval dates for each language version and keep the files together.
7. Check the data lawful basis for any personalised targeting under UK GDPR.

Use this checklist before you sign off the media plan.

• Placement list tagged by nation and local authority
• Advertisement consent checked for every physical format
• Welsh language duty assessed for public-sector partners
• Welsh copy written and approved before English
• Equality Act objective justification recorded where needed
• Both language versions checked against the CAP Code
• Scottish and Welsh data sources cited with reference dates

For the underlying law and its commencement dates, our primary sources page traces each rule to its origin. Build the checks into the launch schedule rather than bolting them on at the end, and a bilingual campaign can run across Scotland and Wales without a last-minute rebuild.

Common questions

Does the ASA regulate Welsh-language advertising? Yes. The CAP Code applies across the United Kingdom, and the ASA accepts and assesses complaints about ads in Welsh as well as English.

Do private retailers have to advertise in Welsh? Generally no, unless they are subject to Welsh language standards or a funding condition. Public bodies and some funded partners do carry those duties.

Is advertisement consent always needed for in-store screens in Scotland? Not always. Screens inside a building usually fall outside planning control, while illuminated or street-facing panels often need consent from the local planning authority.

Where do I find Scottish regional data for a media plan? Start with the Scottish Government statistics and research hub, then use ONS nation and local authority breakdowns to compare with Wales and England.

Can a bilingual campaign target only Welsh speakers? Yes, if the targeting reflects a genuine audience difference. Record the reason, and avoid excluding Welsh speakers from a public-facing offer.

Which body handles Welsh language complaints? The Welsh Language Commissioner investigates complaints about failures to comply with Welsh language standards.