In short Display ads pay for attention: impressions and clicks. Leads and affiliate deals pay for intent: a quote request, a signed contract. You can be paid per lead (CPL), per sale or action (CPA), or with a share of revenue. To make it work you need pages read by people who are about to choose something, a form, consent that is valid for passing data on, and clean leads, because rejected leads are charged back.
Display ads and leads: two different models
With display ads you sell space. An ad network fills it and pays you per impression or per click. It works on almost any topic and grows with traffic.
With lead generation you sell something else: a person who has asked for something. Someone who fills in a form for a loan, an insurance quote or an energy deal becomes a contact that a company will pay for. With affiliate marketing you send the reader to a partner's site through a tracked link and get paid when they take an agreed action.
The two can live on the same site. Ads tend to suit informational pages, forms suit pages where the reader is choosing: comparisons, calculators, buying guides for financial products, insurance or utilities.
Three ways to get paid
| Model | When you get paid | Who carries the risk | What to measure |
|---|---|---|---|
| CPL, cost per lead (pay per lead) | For each valid lead delivered | You on quality, the buyer on conversion | Leads delivered, accepted, charged back |
| CPA, cost per acquisition | When the lead becomes a customer or completes an action | Mostly you | Clicks, confirmed conversions, time to confirm |
| Revenue share | A share of what the partner earns | You, over a long period | Revenue per customer over time |
How the lead is sold matters too. An exclusive lead goes to one buyer. A shared lead goes to several, and the person's consent must cover all of them.
How it is measured: links, postbacks and conversions
Every model needs a measure both sides accept.
- Affiliate links. The link carries a click identifier. The partner records the conversion and ties it to that identifier.
- Postbacks. When a conversion happens, the partner's server tells yours directly, server to server: click identifier, status, amount. No pixel in the browser is needed.
- Lead delivery. The lead goes to the partner through an API, and the partner replies with a status: accepted, rejected, converted.
- Reconciliation. Each month you compare your figures with the partner's before invoicing.
Be careful with identifiers. The EDPB's Guidelines 2/2023 treat a link carrying a per-person identifier like a tracking pixel under Article 5(3) of the ePrivacy Directive. The ICO says PECR regulation 6 applies to link decoration when it stores or accesses information on a device. Use pseudonymous identifiers and never put an email address or phone number in a URL. There is a separate guide on email tracking pixels.
Chargebacks: when a lead is not paid for
After delivery the buyer can reject a lead, or claw back the payment, within a period set in the contract. Typical reasons:
- a duplicate of a lead already received;
- a fake or unreachable contact;
- outside the target, for example by age or area;
- missing consent, or consent that does not cover that buyer;
- fraud: scripted form fills, incentivised traffic, forms completed in bulk.
The contract should list which reasons count, the time limit, the evidence required and how disputes are settled. The best way to cut chargebacks is to stop bad leads before delivery: checks on email and phone, duplicates, form completion speed, and quarantine for unusual sources. That is the job of lead quality controls.
What it takes
- Traffic with intent. Pages where readers are about to choose a product, not just read about it.
- A short, clear form. Only the fields the buyer actually uses.
- Consent that is valid for passing leads on. Separate from consent to your own marketing, naming the recipients, with proof for every lead. The guide on marketing consent for third-party leads covers this.
- Distribution rules. Who gets which lead, exclusive or shared, with what caps: that is lead distribution.
- A contract with every buyer. Data protection roles, proof of consent, chargebacks, payment terms.
- Revenue tracking. Revenue per lead, per source and per partner, fed by postbacks: see lead revenue tracking.
Legal checks before you start
Consent. In the UK, marketing emails and texts to individuals need consent under PECR regulation 22, and the soft opt-in never covers a third party's marketing. The ICO says a buyer must check that the consent named its organisation, not just "trusted partners", covered the channel and is recorded. Under the GDPR you must be able to prove consent (Article 7(1)), and people can object to direct marketing at any time (Article 21).
Accountability along the chain. The ICO's direct marketing guidance tells buyers to carry out proportionate checks before using third-party data: who collected it, how, what people were told, and whether objections are passed on. Expect your buyers to ask you for exactly that.
Loans. In the UK, effecting an introduction of an individual who wants credit to a lender, with a view to a regulated credit agreement, is listed as credit broking, a specified kind of activity, in article 36A of the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001. Whether a paid lead arrangement falls within it, and whether any exclusion applies, is a question for a lawyer before you sign. Insurance leads raise similar questions: ask a lawyer before you start.
Pros and cons compared with display ads
For
- On the right pages each visitor can be worth more, because you are paid for intent rather than views.
- You depend less on a single ad network.
- You build direct relationships with buyers, and a contact base of your own, with consent.
Against
- More work: forms, consent wording, contracts, checks.
- Slower payment, subject to chargebacks.
- More legal exposure: data protection and, in finance and insurance, regulated intermediation.
- Fewer suitable topics: you need sectors where someone pays for a contact.
- Often few buyers: if one leaves, revenue drops at once.
Where to start
- Pick the pages where readers are making a decision.
- Agree the model with the buyer: CPL, CPA or revenue share.
- Write the form and the consent wording, and have a lawyer review them.
- Sign a contract with chargeback reasons, time limits and evidence.
- Set up measurement: postbacks, lead statuses, reconciliation.
- Review chargebacks by source every week and close the sources that lose money.
How we are designing Markmatix for this
Markmatix is in development and is being built for exactly this work. It will collect leads from several sites and forms, with proof of consent inside every lead. It will run checks and a quality score before any lead is passed on, and distribute leads to partners by sector and partner rules. It will record postbacks and revenue per lead, and chargebacks will count against the score of the source that produced them. You can follow progress through the waitlist.
Sources
- Regulation (EU) 2016/679 (GDPR): Articles 7 and 21. EUR-Lex
- The Privacy and Electronic Communications (EC Directive) Regulations 2003 (SI 2003/2426), regulation 22. legislation.gov.uk
- ICO, Guidance on direct marketing using electronic mail, "How do we comply with the PECR electronic mail marketing rules?" (bought-in lists), latest update 28 April 2026. ico.org.uk
- ICO, Direct marketing guidance, "Collect information and generate leads", latest update 28 April 2026. ico.org.uk
- ICO, Guidance on the use of storage and access technologies, "What are storage and access technologies?" (link decoration), finalised April 2026. ico.org.uk
- EDPB, Guidelines 2/2023 on Technical Scope of Art. 5(3) of ePrivacy Directive, version 2.0, 7 October 2024: paragraphs 49-51. edpb.europa.eu
- The Financial Services and Markets Act 2000 (Regulated Activities) Order 2001 (SI 2001/544), article 36A (credit broking). legislation.gov.uk
This guide explains the rules in general and is not legal advice: for your case, ask a lawyer.