FTC disclosure reference for creators

01 / The relationship

When a disclosure may be needed

A material connection is a relationship or benefit that could affect how people evaluate what you say. That can include payment, free or discounted products or services, affiliate compensation, employment, a family or personal relationship, or another incentive or benefit. See 16 CFR § 255.5 for the rule’s treatment of unexpected material connections.

An ordinary, self-funded mention of a product when you have no relationship with the brand is a different fact pattern. That distinction does not decide whether a particular post is compliant; the facts and the full communication matter.

02 / The placement

What “clear and conspicuous” means

The FTC’s standard is practical: people should be able to notice and understand the disclosure without working to find it. The definition in 16 CFR § 255.0(f) also connects the disclosure to the way the endorsement is communicated.

• Make it easy to notice: use straightforward words, enough contrast, and a size and duration people can actually perceive.
• Make it easy to understand: say what the relationship or benefit is in ordinary language.
• Make it unavoidable in interactive media: do not put the only disclosure somewhere viewers must click or expand to see.
• Keep it close to the endorsement: place it with the post, image, video, audio, or other recommendation it explains.
• Match the communication mode: visual endorsements need a visual disclosure, audio endorsements need an audible disclosure, and content using both should use both.

For that reason, a platform’s built-in disclosure tool may not be sufficient by itself. Check the FTC’s Endorsement Guides Q&A and Disclosures 101 for current staff explanations rather than assuming a platform feature answers every situation.

03 / The wording

Examples creators can adapt

The following are illustrative starting points, not legal-safe-harbor templates or guarantees. Adapt the wording so it accurately names your relationship and matches the format of your content.

04 / The endorsement

Keep the endorsement truthful

An endorsement should reflect your honest experience, opinion, or belief. Do not say or imply that you used a product you have not tried, and do not make product claims that you cannot support. Read 16 CFR § 255.1 alongside the FTC’s creator guidance for the principles behind this reminder.

05 / Before you publish

Before you publish

1. 01Identify the relationship: payment, product, commission, employment, family or personal connection, incentive, or another benefit.
2. 02Name the benefit in ordinary language so viewers do not have to decode it.
3. 03Place the disclosure where viewers will see it alongside the endorsement.
4. 04Match it to the content: include it in the visual, audio, and/or video portion as the communication requires.
5. 05Check the claim itself: speak from an honest experience and avoid unsupported product claims.