03/11/2023. London, United Kingdom. DESNZ Secretary Claire Coutinho meets German Vice-Chancellor Robert Habeck for a bilateral meeting at the Foreign Commonwealth and Development Office where they signed a UK-Germany Energy & Climate Partnership . Picture by Dan Dennison / DESNZ
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Rules and ethics

Part of Lead marketplaces: consent basics for UK publishers

Lead marketplaces: consent basics for UK publishers

Lead marketplaces raise consent and data-sharing questions for UK publishers. This guide covers lawful bases, payment models and a pre-launch checklist.

What to take away

  • UK publishers can sell leads, but the record must show consent and source.
  • Finance, legal and education leads pay more, and carry stricter rules.
  • Most deals pay per accepted lead, qualified call or sale, not per click.
  • UK GDPR needs a lawful basis before data goes to a buyer.
  • Test one vertical and one tracking route before adding partners.

What publishers are actually selling

When selling to lead marketplaces, a publisher sells an introduction with a permission trail. The buyer wants a person who expects contact and matches its criteria.

The publisher must keep evidence of the page, the form wording and the time of consent. That evidence decides whether the lead is accepted.

A marketplace may reject a lead if the person cannot be reached or did not agree to the buyer's category.

Lead marketplaces often publish acceptance criteria, but the publisher cannot see every buyer rule. The deal should state how long a record stays valid, how duplicates are handled and what proof is needed for a rejected lead.

A publisher that tracks those details can price its traffic with more confidence.

The rules that shape a UK lead sale

The ICO's direct marketing guidance explains consent, soft opt-in and the need to name the buyer or category. If you rely on consent, it must be specific and recorded. Electronic marketing is also governed by the Privacy and Electronic Communications Regulations 2003 (PECR).

If you use legitimate interests, you still need a balancing test and a clear opt-out. Our guide to legitimate interest versus consent for bought leads sets out the records to keep.

The UK GDPR text sets out the lawful bases, including consent and legitimate interests.

Finance leads sit under the FCA's Consumer Duty when the buyer gives advice or arranges products, so the lead must not mislead.

The buyer must use the data for the purpose the person agreed to and keep its own record.

If a publisher sends data without a clear basis, both sides carry risk. A short data sharing agreement should name the categories, the retention period and the deletion route.

Payment models and what affects publisher revenue

Publisher lead revenue share is not one number. It depends on the sector, the buyer's close rate and the quality checks.

Lead payment models compared

Pay per lead

Publisher paid on
Accepted lead
Main risk
Rejections
Payment timing
On acceptance

Pay per qualified call

Publisher paid on
Agreed call time
Main risk
Call handling
Payment timing
After call

Pay per sale

Publisher paid on
Completed purchase
Main risk
Long tracking
Payment timing
Pays later

A finance lead may pay more than a general insurance enquiry, but the buyer will audit consent.

A legal lead may pay per qualified call rather than per form. A sale-based deal pays later and needs a tracking clause.

Ask what happens when a lead is rejected, duplicated or refunded.

Revenue share and pricing

Publisher paid on

Pay per lead
Accepted lead with valid contact details
Pay per qualified call
Call lasting an agreed time and within category
Pay per sale
Completed purchase or signed instruction
Revenue share
Percentage of buyer revenue for a period

Main risk

Pay per lead
Rejections and duplicate rules
Pay per qualified call
Call handling and recording
Pay per sale
Long tracking window
Revenue share
Attribution and refunds

Cost per lead varies by sector and deal terms; our cost per lead benchmarks discuss what buyers pay by sector.

If a buyer rejects leads after a quality check, the publisher carries the cost of that traffic.

The contract should state the rejection reasons and the evidence needed to challenge a decision.

A publisher that records source, consent and call outcomes can compare net revenue across buyers. That record also supports a fairer revenue share in the next negotiation.

A checklist before you connect traffic

  1. Draw a data mapwhat you collect, why, where it is stored and which buyer receives it.
  2. Write the form wording in plain English, naming the buyer or a clear category.
  3. Record consent or the legitimate interests assessment, with a timestamp.
  4. Test the hand-off with dummy data and check rejection reasons.
  5. Set a review date for the contract, the data and buyer requirements.

Common questions

Do I need consent to sell leads in the UK?

You need a lawful basis, and consent is the safest route for third-party marketing. If you rely on legitimate interests, record the assessment and offer a clear opt-out. The ICO's guidance applies to electronic marketing.

What data must I give a lead buyer?

Give only the data the buyer needs and that the person agreed to share. That usually means contact details, the enquiry topic, location and the consent record. Do not pass special category data without a separate condition.

How much can a UK publisher earn per lead?

There is no single rate. Finance, legal and education leads often pay more than general consumer leads, but rejection and refund rules reduce the net figure. Model the accepted rate, not the advertised rate.

Which sectors pay best for publisher leads?

Sectors with high customer value and strict advice rules tend to pay more. That includes mortgages, personal injury, insolvency and some education courses. Check the buyer's permissions and the advert claims before you send traffic.

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