If you’ve ever wondered whether the free product or affiliate link you’re about to post needs a disclosure, the FTC guidelines for influencers have the short answer: yes. The guidelines make clear that if you have a material connection to a brand, you need to say so every time you post about it.
That rule applies to both sides of a partnership. Creators are responsible for disclosing, and the brands, agencies, and platforms that pay them share responsibility for making sure it happens. For brands running creator programs at scale, that shared liability is critical to get right.
The basics haven’t changed much since the FTC published its Disclosures 101 guide in 2019. But there are a few updates to make note of for anyone working in creator marketing. The FTC revised its Endorsement Guides in 2023, finalized a rule banning fake and AI-generated reviews in 2024, and sent its first warning letters under that rule in December 2025.
Below, we’ll cover what counts as a material connection, how to disclose on every major platform (with caption examples), what brands owe their creators, and a checklist to run before every sponsored post.
Table of Contents
What the FTC guidelines say
Every part of the FTC influencer guidelines comes back to one idea: a material connection. The FTC defines material connection as any financial, employment, personal, or family relationship with a brand. If you have one, you disclose it, even if you think your review is unbiased and even if your followers already know about the partnership.
What counts as a material connection
A financial relationship doesn’t have to involve money. Any of these counts:
Payment for a post
Affiliate commissions on sales from your link
Free or discounted products, services, or trips
Perks like early access or event invites
Personal ties, such as a friend, family member, or employer at the brand
For example, let’s say a brand sends you free products and you later post about any of its products. You have to disclose it, even if the brand didn’t ask you to post.
Who has to follow these guidelines
Creators, wherever they live: US law applies if it’s reasonably foreseeable that US consumers will see your post, and other countries’ laws may apply too.
Brands, agencies, and platforms: If you pay or work with creators, you’re also responsible for ensuring disclosure happens.
Also important to note: Under the FTC social media guidelines, tags, likes, pins, and similar signals count as endorsements, so they need a disclosure when there’s a connection.
Once you know you have a material connection, the next question is how to say so. The FTC disclosure guidelines set one standard: “clear and conspicuous,” meaning people should notice and understand the disclosure without looking for it. That comes down to three choices: the words you use, where you put them, and how you adapt them to each format.
Words that work and words that don’t
Plain words work best. Any of these make the relationship clear:
#ad or “Ad”
#sponsored or “Sponsored”
“Paid partnership with [Brand]”
“[Brand] sent me this for free”
“I earn a commission from this link”
Vague or insider terms can be misread. The FTC specifically calls out “sp,” “spon,” and “collab,” along with “thanks” or “ambassador” on their own. Abbreviated brand names can cause the same problem. In 2023, the FTC flagged posts that disclosed a partnership with “ameribev” because viewers might not know it meant the American Beverage Association.
Disclose on every sponsored post, including the tenth one in a long-running partnership. Someone who sees one post may never see the others.
Placement is also important. Put the disclosure where people will see it before they scroll through. This can be:
In the first line of a caption, before the “more” cutoff
Apart from a block of hashtags, where it’s easy to skim past
In the post itself, rather than only in your bio or the comments
In the same language as the rest of the post
Let’s use this Reel from creator Bonnie Barton (@flashesofstyle) as an example of how to get disclosure right. Snuggle is tagged as a collaborator, the caption opens with #SnugglePartner, and ‘Snuggle Partner’ appears on screen as visual reinforcement.
https://www.instagram.com/flashesofstyle/reel/Der1zOitf9a/
What it looks like in a caption
Instagram feed post
Unclear: Six weeks into this serum and my skin has never looked better. #skincare #glowup #morningroutine #selfcare #skinceuticals #ad
Clear: #ad I’ve used SkinCeutical’s vitamin C serum every morning for six weeks, and it’s the first one that hasn’t irritated my skin. Link in bio.
TikTok video
Unclear: The caption says “my holy grail serum,” and the disclosure appears only in a pinned comment.
Clear: The caption opens with “Paid partnership with SkinCeutical’s,” and the branded content setting is on.
YouTube video
Unclear: “This video is sponsored by SkinCeutical’s” appears in the description, below the “show more” fold.
Clear: Before the segment, the creator says “SkinCeutical’s is sponsoring today’s video” on camera, with matching text on screen and the paid promotion setting turned on.
Be mindful of the platform’s specific requirements and formatting to ensure the disclosure is placed in a way that users are likely to see it.
A built-in label falls short: it can be small, easy to miss, or missing from reposts and cross-posts. Use it on top of your own words, not instead of them.
Here’s a quick guide:
Format | Where the disclosure goes |
Static post | In the first line of the caption, above the “more” cutoff |
Stories and Reels | On top of the image or video, on screen long enough to read |
Video | In the video itself, said out loud and shown on screen, with the description as a backup |
Live stream | Repeat it throughout, since viewers join and leave at different points |
Podcast | Said out loud before the endorsement |
Affiliate links | Next to the link, wherever it appears |
Why a platform label isn’t enough
Instagram, TikTok, and YouTube each offer a built-in label or setting for branded content. These should be turned on. Some platforms require them for paid posts, and the FTC’s own advice is to use them alongside your disclosure, never in place of it.
A label can be small, easy to scroll past, or lost when a post is reposted or shared to another platform. Including your own words in the caption is what makes the disclosure hold up.
How to write a CPG creator brief around shopper mindset
First, name your growth goal. Do you want new buyers, new occasions, more frequent use, a reason to trade up, or stronger loyalty? Your answer tells you whose decision needs to change.
Then fill in this assignment:
For [shopper] in [purchase mindset], help them [decision] by showing [specific content]. We need a creator whose existing work demonstrates [relevant capability].
For detergent, “show the supported stain-removal benefit” and “make the correct bottle memorable before the next shop” give you different evidence to look for in a creator’s portfolio.
Keep the objective precise and invite the creator’s execution.
“Creators aren’t there to be mouthpieces for every point a brand wants to make,” Beauregard explains. “They’re storytellers, and their strength is showing how a product fits into real human experiences.”
Before approving the next shortlist, identify the shopper’s decision and the capability it requires. Then ask which scene in the proposed content will help someone make that decision. Explore Later’s influencer marketing services.
