For creators

FTC disclosure for UGC creators

Updated 7 min read For creators

Questions people ask

Do I have to disclose if I only got a free product?
Yes. The FTC says free or discounted products count as a material connection, even if you were not paid in money and even if you think your review is unbiased.
Is #ad enough?
The FTC says #ad, Ad: and the word ad at the start of a post are about equal and work. It also says a disclosure in the middle or end of a post, or among other hashtags, is easy to miss.
Where does the disclosure go in a video?
In the video itself, both spoken and on screen when the endorsement is spoken and shown, and near the start. A caption-only or comment-only disclosure is not enough, per the FTC.
Does the paid partnership label on Instagram or TikTok cover me?
Not on its own. The FTC's 2023 update says a platform's built-in tool might not be an adequate disclosure, and its influencer guidance says not to rely solely on it. Use the tool and say it in the video.
What happens if I do not disclose?
The FTC can act against the brand and the endorser. The maximum civil penalty for a knowing violation of an FTC rule is $53,088 per violation, unchanged for 2026.

Sources

  1. FTC, Disclosures 101 for Social Media Influencers · ftc.gov
  2. FTC, Endorsement Guides: What People Are Asking · ftc.gov
  3. FTC, updated Endorsement Guides, 29 June 2023 · ftc.gov
  4. FTC, final rule banning fake reviews and testimonials, 14 Aug 2024 · ftc.gov
  5. FTC, inflation-adjusted civil penalty amounts for 2025 · ftc.gov
  6. FTC, civil penalty amounts unchanged in 2026 (Federal Register, 15 Sep 2026) · federalregister.gov
  7. TikTok, Branded Content Policy · tiktok.com
  8. YouTube Help, paid product placements, sponsorships and endorsements · support.google.com
  9. HourlyUGC blog, partnership ads from the creator's handle · hourlyugc.com