This article is part of the Iris Ethics Knowledge Base; you can find a directory of all articles here.
"Market research is covered by industry standards, so the National Statement doesn't apply, right?"
Market research has its own well-developed governance, and that is part of why this question comes up. Providers work to ISO 20252, the international standard for market, opinion, and social research, and to sector codes administered through bodies such as The Research Society. These frameworks are real and they are audited. The mistake is treating them as an alternative to ethics review rather than something that runs alongside it.
Two things are worth separating. The first is whether market research is human research at all. Under the National Statement, it very often is. Collecting attitudinal or behavioural data linked to individuals through surveys, interviews, or focus groups is human research even when results are only ever reported in aggregate and no individual is named. The fact that the data ends up as percentages in a report does not change what happens at the point of collection. Industry standards govern how that collection is done well. They do not remove the activity from the scope of the National Statement, and they do not by themselves grant an exemption.
The exemption categories are narrow, and they are worth knowing precisely. Research using genuinely public data, or aggregate data, sits outside human research. So does a study restricted to surveys or observation of public behaviour that collects no personal identifiers and is highly unlikely to cause distress. A bespoke attitudinal survey that captures demographics and individual responses is none of these things. And under NS 5.1.16, research that uses personal information without consent cannot be exempted at all; a waiver of consent would have to be granted by an ethics review body first. Exemption and waiver are different mechanisms, and neither is automatic.
The second thing worth separating is a structural quirk that catches well-run projects off guard: participant incentives in panel-based research. When you contract a panel provider to deliver a sample, the incentive paid to respondents is usually set by the provider and treated as commercial-in-confidence. The National Statement, meanwhile, expects incentives to be disclosed (2.2.6(j)), proportionate (2.2.10 to 2.2.11), and assessed for any pressure they place on voluntariness (3.1.21). The honest position is that the applicant frequently cannot state the dollar figure, because it is structurally unavailable to them. This is a governance gap rather than an ethical failure, and it is one a committee can work with if you name it. We cover the practical options in detail in our resource on market research panels and the National Statement.
Two examples show how the risk profile drives the answer. A 12-minute, de-identified, general-population survey measuring awareness of a government service is the kind of omnibus work that is typically lower risk; confirming the panel's ISO 20252 certification and describing the incentive mechanism honestly will usually be enough. By contrast, a survey deliberately recruiting people on low incomes to explore financial hardship raises a real risk that payment exerts undue influence, because participants in financial stress may have less capacity to decline. The safer course is to specify the incentive yourself, assess its proportionality, and document that assessment.
The broader point is that the National Statement was written with clinical paradigms front of mind, while market research operates through its own parallel governance. The two are complementary, not competing. Confirming you meet ISO 20252 is good practice. It is not a substitute for working out whether your project needs review, and at what level. If you are unsure, contact us, or check out our other resources. Our Navigator flow chart and our resource on what exemption actually means are good places to start.
This page was last updated on 21 September 2026.
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This article makes reference to the National Statement on Ethical Conduct in Human Research 2025. It is intended as practical guidance and does not constitute legal advice.
AI Disclosure: Resources in this library were prepared using Large Language Models with input from Iris Ethics staff who guided the scope and design. Subsequent revisions and final versions were developed and approved by Iris Ethics staff.