FTC Guidelines for Influencers: What Brands Need to Know

Last updated: November 2026

The FTC guidelines for influencers say that anyone who endorses a product must clearly disclose a "material connection" to the brand, such as payment or free products. Brands share the responsibility: the FTC expects you to train influencers, tell them how to disclose, and make a reasonable effort to monitor what they post.

This guide is for brands, marketers and founders who hire creators and want a practical compliance routine. It summarizes FTC pages we opened in November 2026. It is not legal advice, so talk to a lawyer about your specific campaigns.

What the FTC guidelines for influencers actually are

The core document is the FTC's Endorsement Guides. They explain how advertisers and endorsers can keep endorsements truthful. The FTC published a revised version in June 2023, and its announcement lists what changed. Among the updates: a definition of "clear and conspicuous," a note that a platform's built-in disclosure tool might not be an adequate disclosure, and clearer language on the liability of advertisers, endorsers and intermediaries.

The FTC also publishes two plain-language pages worth bookmarking. Disclosures 101 for Social Media Influencers is written for creators. The FTC's Endorsement Guides: What People Are Asking answers questions from both creators and advertisers.

When a creator has to disclose

Per the FTC, a creator must disclose a "material connection" with a brand. That includes a personal, family or employment relationship, or a financial relationship such as the brand paying them or giving them free or discounted products or services.

• Paid posts. Any post a creator makes in exchange for payment needs a disclosure.
• Gifted products. The FTC says financial relationships aren't limited to money. If a creator got anything of value to mention a product, they should disclose it.
• Tags, likes and pins. The FTC notes these can be endorsements too.
• No relationship. If a creator bought a product themselves and just likes it, they don't need to say they have no brand relationship.

How the FTC says disclosures should look

The FTC's advice is that people must see and understand the disclosure. Build these points into your creator instructions.

• Put it with the endorsement. The FTC says disclosures are likely to be missed on an About Me or profile page, at the end of a post or video, or anywhere a viewer must click "more."
• Don't bury it in hashtags. The FTC says not to mix the disclosure into a group of hashtags or links.
• In video, show it in the video. For video endorsements, the disclosure should be in the video itself, not only in the description. The FTC says viewers are more likely to notice disclosures made in both audio and video.
• Images and Stories. Superimpose the disclosure over the picture and leave enough time to read it.
• Live streams. Repeat the disclosure periodically for people who only see part of the stream.
• Use plain words. The FTC says terms like "advertisement," "ad" and "sponsored" work. It advises against vague terms like "sp," "spon," or "collab," and stand-alone terms like "thanks" or "ambassador."
• Don't rely on the platform tool alone. The FTC says not to assume a platform's disclosure tool is good enough, but to consider using it in addition to a good disclosure of your own.

What brands are responsible for

This is the part most brand guides skip. In the FTC's FAQ, the agency says advertisers need reasonable programs to train and monitor the people promoting them. It lists four elements every program should include:

1. Tell creators what they can and can't say about your products, especially objective claims you must be able to substantiate.
2. Instruct creators on their duty to disclose, including exactly how you want them to do it.
3. Periodically search for what creators are saying.
4. Take appropriate action if you find questionable practices.

The FTC says it's unrealistic to expect you to know every statement a creator makes, but you need to make a reasonable effort. It also says it's unlikely that one rogue influencer would be the basis of a law enforcement action if you have a reasonable training, monitoring and compliance program in place.

The FTC adds that if you send free, unsolicited products and nothing else, you should still ask creators to clearly disclose the gift, tell them how, and ask them to tag the brand. You're also still responsible for deceptive claims they make about the product. And if an agency runs your creator program, the FTC says delegating doesn't relieve you of responsibility under the FTC Act.

Pre-approve paid posts

The FTC's FAQ says that if you pre-approve paid posts, you should review them for truth-in-advertising compliance, including disclosures. If you don't have a pre-approval process, it suggests considering one, because it is much easier to review posts before they go live than to search for them afterward. For short-lived formats like Instagram Stories, the FTC says there's probably no practical way to monitor in real time, so it recommends requiring approval in advance.

When you work with creators on UGC and influencer content, build one review step into the schedule: draft or script first, then the finished post, each checked for claims and disclosure.

A brand compliance checklist

1. Write the disclosure rule into the brief. Say which words to use ("ad" or "sponsored") and where they go for each format.
2. List allowed and banned claims. The FTC says creators can't make up claims that would require proof the advertiser doesn't have, such as scientific proof that a product treats a health condition.
3. Require honest use. The FTC says creators can't talk about their experience with a product they haven't tried, or call a product terrific if they thought it was terrible.
4. Put the same rules in the contract. A written agreement gives you something to point to if a post goes wrong.
5. Approve before posting. Get drafts or scripts for paid posts.
6. Monitor after posting. The FTC says to monitor for the length of the contract and a reasonable time after, such as a few months, with no set period for every case.
7. Fix problems fast. If you learn a creator is making bad claims or skipping disclosures, don't ignore it.

Common questions brands get wrong

• "The creator is responsible, not us." The FTC's Disclosures 101 says it's the influencer's responsibility to disclose. The FTC FAQ also says advertisers are on the hook for deceptive claims and need a training and monitoring program. Both can be true at once.
• "We only sent free product." Training material is important but insufficient, per the FTC. Ask for a clear disclosure of the gift, explain how, ask for a tag, and monitor the tagged posts.
• "The creator is outside the US." The FTC says U.S. law applies if it's reasonably foreseeable that a post will affect U.S. consumers, and foreign laws might also apply.
• "The platform has a paid partnership label." The FTC says not to assume a platform's tool is enough on its own. Use it in addition to a clear disclosure in the post.
• "We use monitoring software." The FTC takes no position on the quality of such software. It says the extent of monitoring needed may depend on the product and the claims involved, for example health or safety claims.

How to build this into your creator workflow

Compliance is easiest when the brief carries it. A brief that states the deliverable, the claims allowed and the disclosure format means every creator gets the same instructions. Jem's campaign brief generator is a free place to start a structured brief.

On Jem Social, brand accounts are free and no card is needed, and posting a brief is free. Jem's AI writes a brief from one line in about 4 minutes. Creators apply, and you see everyone who applied in one place. Booking creators needs the paid plan, which has a 7-day free trial; see pricing. Jem is a place to find and brief creators. The legal duty to disclose and monitor stays with you and the creator, so keep your own review step. If you want to compare creator sizes for your next campaign, read influencer tiers explained.

Send your first compliant brief this week

Add a disclosure line and a claims list to your next creator brief, then post it free on Jem Social and let creators apply.