What do FTC disclosure rules require?

The FTC requires that any material connection between an endorser and a brand, payment, free product, an affiliate commission, an employment or family relationship, be disclosed clearly and conspicuously so consumers understand the endorsement is sponsored. It also requires that endorsements and reviews be truthful and reflect honest opinions, and that you not fabricate or suppress reviews. The core principle is that advertising should not mislead, and undisclosed paid endorsements mislead.

Do FTC rules apply to the brand or the influencer?

Both. Influencers and endorsers are responsible for their own disclosures, but brands are also responsible for the endorsements made on their behalf, including instructing creators to disclose and monitoring that they do. You cannot offload the responsibility entirely onto the creator. A brand that pays for endorsements without ensuring proper disclosure carries its own liability, which is why compliant influencer and affiliate programs build disclosure into the process.

How should a disclosure be made?

Clearly and conspicuously, in a way the average consumer will actually notice and understand, placed where they will see it before or as they engage with the endorsement, not buried in a comment, hidden behind a more link, or lost in a string of hashtags. Plain language like a clear ad or sponsored label is better than vague or ambiguous wording. The standard is whether a typical consumer would readily understand the relationship.

What are the risks of ignoring FTC disclosure rules?

The FTC can pursue enforcement actions against both brands and endorsers for deceptive advertising, leading to penalties and required changes, and noncompliance damages consumer trust and can trigger marketplace issues. Beyond regulation, undisclosed or fake endorsements erode the credibility that makes the marketing work. Building disclosure and truthful endorsements into your process protects you legally and preserves the trust your reviews and influencers are meant to create.

Playbook Compliance-safe marketing

FTC disclosure rules for ecommerce and creators

If you work with influencers, run affiliates, or use reviews and endorsements, FTC disclosure rules apply to you, not just the creator. Here is what they require and how to keep your marketing compliant.

August 11, 2026 7 min read

If you work with influencers, run an affiliate program, or use endorsements and reviews in your marketing, FTC disclosure ecommerce rules apply to you, and not only to the creators you work with. The rules exist to stop advertising from misleading consumers, and undisclosed paid endorsements do exactly that. Here is what the FTC requires, who is responsible, and how to keep your marketing compliant without losing its punch.

What FTC disclosure ecommerce rules require

Two core requirements run through the FTC endorsement rules and the broader FTC influencer guidelines:

Disclose material connections. Any meaningful relationship between an endorser and your brand, payment, free product, an affiliate commission, employment, family, must be disclosed clearly and conspicuously, so consumers know the endorsement is sponsored.

Keep endorsements truthful. Endorsements and reviews must reflect honest opinions and real experiences. You cannot fabricate reviews, suppress unfavorable ones, or have endorsers claim things that are not true.

The principle beneath both: advertising should not mislead, and a paid endorsement that looks like an independent opinion misleads.

The rule is simple even when the cases are not: if money, product, or a commission changed hands, the audience has a right to know before they trust the recommendation.

Who is responsible

The brand shares the liability

Influencers are responsible for their own disclosures, but you, the brand, are also responsible for endorsements made on your behalf. You cannot offload it entirely onto the creator. That means instructing creators to disclose, building it into your agreements, and monitoring that they actually do.

Build disclosure into the program

Compliant influencer and affiliate programs do not rely on each creator remembering. They build the affiliate disclosure into the brief, the contract, and the review process, so compliance is the default, not an afterthought left to chance.

Disclose so people actually understand

Clear, conspicuous, and unmissable

A disclosure has to be something the average consumer will notice and understand, placed where they see it as they engage with the endorsement, not buried in a comment, hidden behind a more link, or lost in a wall of hashtags. Plain labels like a clear ad or sponsored beat vague wording. The test is whether a typical person would readily grasp the relationship.

FTC disclosure compliance

Disclose every material connection: payment, product, commission, relationship
Keep all endorsements and reviews truthful and genuine
Never fabricate reviews or suppress honest unfavorable ones
Remember the brand shares responsibility, not just the creator
Build disclosure into briefs, contracts, and review processes
Make disclosures clear, conspicuous, and unmissable
Get qualified guidance for your specific programs and claims

FTC disclosure sits alongside the rest of your compliance-marketing discipline, the same care you apply to the claims you make about products applied to the endorsements others make on your behalf. Handled well, it costs you nothing in effectiveness and protects both your legal standing and the consumer trust that makes endorsements work in the first place.

If you run influencer or affiliate marketing and want to be sure your disclosure practices are compliant, building that into your process is exactly the kind of risk-reducing work a Growth Audit can help scope.