A creator delivers a campaign, the content is approved, and finance asks for an invoice. The creator replies that they do not have a company, VAT number or self-employed registration. Can brands pay unregistered creators? Usually, yes. But sending money is the easy part. Paying them with the right legal, tax and accounting trail is the operational challenge.
For brands and agencies running creator, affiliate or UGC programmes, an unregistered creator should not automatically be excluded. Equally, they should not be treated as an informal supplier with no paperwork. The correct approach depends on where the creator is based, what “unregistered” means in their case, the nature of the work, and how the payment is structured.
Can brands pay unregistered creators? Yes, with the right process
A business can generally pay an individual for legitimate services without that person owning a limited company or being VAT registered. In the UK, for example, a creator may trade as a sole trader, may be below the VAT threshold, or may be completing an occasional commercial collaboration while they establish whether they need to register for self-assessment.
Those are different situations. A missing VAT number does not mean a creator cannot be paid. A missing company registration does not mean there is no valid commercial relationship. But an absent tax registration, invoice or proof of identity can create questions that finance teams cannot safely ignore.
The practical rule is simple: do not use the creator’s registration status as a shortcut for compliance. Establish who is being paid, what they delivered, where they are tax resident, whether any withholding or reporting duty applies, and what document supports the payment.
For a campaign involving 80 creators across the UK, Spain, France and the US, this cannot be managed reliably through a shared spreadsheet and ad hoc bank transfers. Each country can have different expectations around invoices, tax declarations, identity verification and reporting. The risk grows with every new payee.
“Unregistered” can mean several different things
Before approving payment, clarify the creator’s actual status. The term often hides very different facts.
A creator may be an individual without a company. They may operate as a sole trader but not be VAT registered. They may not yet have registered for local income tax. Or they may simply be unable to produce a conventional invoice in the format your accounts payable process expects.
These cases require different treatment. A UK creator who is not VAT registered should not charge VAT. A creator outside the UK may need to provide a local tax identifier or a declaration of tax residency. A US creator may need to complete a W-9, while non-US payees may require a W-8 form where relevant to the payment flow.
There is also a separate employment-status question. If a brand controls the creator’s working hours, methods, equipment and ongoing activity in a way that resembles employment, calling the payment a “creator fee” will not remove the risk. Most one-off content collaborations are supplier relationships, but high control, regular work and exclusivity can change the analysis.
What a compliant payment file should contain
The objective is not to collect every possible document. It is to maintain enough evidence to explain the transaction to auditors, tax authorities and your own finance team.
For each creator, retain verified identity details, payment details, tax residency information where required, the agreed scope of work, approval evidence and the payment record. The agreement should state the deliverables, fee, currency, usage rights and whether the amount includes any applicable taxes.
The payment document matters too. If a creator cannot issue an invoice, the brand may need an alternative compliant document, such as a self-billed invoice where local rules permit it. Self-billing is not merely creating an invoice on someone else’s behalf. It requires a valid arrangement and correct information, including treatment of VAT where applicable.
For cross-border payments, finance should also record the legal payee, country, currency, exchange rate where relevant and any fees deducted. Without this data, month-end reconciliation becomes manual, and reporting obligations become harder to meet.
The risks of paying first and documenting later
Teams often make an exception for a small campaign fee. Then the programme scales, the exceptions become the process, and finance inherits a fragmented payment history.
The first risk is tax and VAT treatment. If the creator has charged VAT incorrectly, or the brand has no evidence supporting the tax treatment, correcting invoices and returns later is expensive. If local withholding tax applies and was not considered before payment, the company may have to absorb the liability.
The second risk is supplier fraud and misdirected payments. Creator programmes frequently involve last-minute changes to bank details, managers receiving payment on behalf of talent, and collaborators based in countries different from the audience market. Basic KYC and payment validation reduce the chance of paying the wrong party.
The third is reporting. Depending on the payment model and jurisdictions involved, platforms and businesses may have obligations connected to DAC7, US tax forms, local income reporting or audit trails. The details depend on the role of each party, but lack of source data makes compliance difficult regardless of the final obligation.
Finally, there is operational cost. Processing 150 individual invoices, chasing missing tax information and resolving failed international transfers can consume more time than the campaign itself. The creator sees a delayed payment. Finance sees a supplier record that cannot be closed.
A workable process for paying individual creators
The strongest workflow separates commercial approval from compliance approval and payment execution.
First, marketing or the agency approves the creator, deliverables, rights and fee. This avoids finance trying to infer whether a payment was authorised from a chat thread or a social media brief.
Second, collect and validate the creator’s onboarding data before the work is completed where possible. This includes identity, tax and payout information, plus consent to the invoicing arrangement. If information is incomplete, the payment should be flagged before it enters the batch.
Third, execute the payment through a controlled process that creates a clear record. The business should be able to see who approved it, what was paid, in which currency, on what date and against which campaign. For large programmes, batch payouts with multi-level approvals are far more reliable than individual bank transfers.
This approach does not mean every creator needs to become a corporate supplier in your ERP. It means each payment has a defensible legal and financial basis.
When direct payment is not the best model
Direct payment can work well for a small domestic programme with a handful of well-known creators. It becomes less attractive when a brand pays across borders, works with high volumes, or accepts creators who do not have a business entity or conventional invoicing capability.
At that point, a merchant of record model can remove the structural bottleneck. Instead of contracting, collecting documents, receiving invoices and paying every creator separately, the company works with one legal intermediary. The intermediary manages creator onboarding, compliant invoicing, tax documentation and payout execution, while the brand receives one consolidated invoice for the approved batch.
Zexel Pay is designed for this operating model. It enables payments to creators and digital partners in more than 150 countries and over 30 currencies, including cases where the recipient does not have a company or VAT number. For the brand, the value is not simply faster payment. It is one invoice, controlled approvals and tax administration outsourced from the campaign workflow.
Give creators a route to be paid properly
Excluding every creator who is not VAT registered or incorporated will narrow your talent pool, particularly for emerging creators and one-off UGC contributors. Paying them with no checks creates a different problem: weak records, avoidable tax exposure and payment operations that fail under scale.
The practical middle ground is to treat unregistered creators as legitimate payees who need an appropriate payment route. Build the evidence before the payout, apply the rules that match the jurisdiction, and use infrastructure that does not force your finance team to become a global compliance desk.
