Influencer partnerships disclosed with #ad or equivalent

The FTC Endorsement Guides hold advertisers liable for influencer disclosures even when the influencer fails to disclose — if the brand did not take reasonable steps to require and monitor compliance. A creator program that pays commissions but provides no disclosure guidance in its terms exposes the brand to FTC enforcement every time a partner posts without #ad or #sponsored. Embedded influencer social content on the site that lacks a disclosure label is an additional violation on the brand's own property, where the brand has direct control.

Add disclosure requirements to partner program terms and label any influencer content embedded on the site.

// Embedded influencer content — label it if the relationship is paid
function InfluencerEmbed({
  post, isPaid
}: { post: SocialPost; isPaid: boolean }) {
  return (
    <div className="social-embed">
      {isPaid && (
        <p className="text-xs text-gray-500 mb-1">Paid partnership</p>
      )}
      <EmbeddedPost post={post} />
    </div>
  )
}

Add to partner program terms and onboarding email:

## Disclosure requirements for all creator and affiliate partners

All promotional content for [Product] must clearly disclose our
commercial relationship before the main promotional content.

Acceptable formats: #ad · #sponsored · #[ProductName]Partner ·
"This is a sponsored post" · "I'm a paid partner of [Product]"

Disclosure must be clearly readable — not buried in hashtags —
and present on every promotional post. Failure to disclose exposes
both you and [Product] to FTC enforcement action.

• ID: ftc-consumer-protection.endorsement-disclosure.influencer-partnerships-disclosed

• Severity: medium

• What to look for: Count all relevant instances and enumerate each. Check whether the application has an influencer or creator program — look for /affiliates, /partners, /creators, or similar pages. Look for influencer management integrations (GRIN, Aspire, CreatorIQ, or similar tools in dependencies). Check marketing assets, press kits, or influencer brief documents in the repository. If influencer relationships exist, determine whether the application provides (or requires) guidelines for disclosure. Note: this check evaluates the application-side infrastructure and guidelines — you cannot audit the actual social posts directly, but you can check whether the company has a disclosure requirement in place and communicates it to partners. Also check the application's own social media integrations or embedded social content for any influencer posts that are embedded without disclosure.

• Pass criteria: The influencer or creator program page (if it exists) explicitly requires disclosure in all promotional content using #ad, #sponsored, or equivalent language per FTC guidelines. At least 1 implementation must be verified. Embedded influencer social content on the site includes disclosure. Influencer onboarding materials or contracts reference disclosure requirements.

• Fail criteria: An influencer or creator program exists with no disclosure requirement documented. Partner onboarding materials do not mention disclosure obligations. The application embeds social content from paid influencers without any disclosure label.

• Skip (N/A) when: The application has no influencer program, no creator partnerships, and does not embed third-party social content from paid partners.

• Detail on fail: Example: "Affiliates page exists and includes a commission structure, but the program terms do not mention FTC disclosure requirements for social promotion." or "Creator program landing page has no disclosure guidance. No mention of #ad or #sponsored requirements in onboarding flow." or "Embedded Instagram posts from paid partners on the homepage have no disclosure label."

• Remediation: Add disclosure requirements to partner materials and any embedded social content:

  // If you embed influencer social content, label it
  function InfluencerEmbed({
    post, isPaid
  }: { post: SocialPost; isPaid: boolean }) {
    return (
      <div className="social-embed">
        {isPaid && (
          <p className="text-xs text-gray-500 mb-1">
            Paid partnership
          </p>
        )}
        <EmbeddedPost post={post} />
      </div>
    )
  }
  

  # Disclosure requirements for all creator and affiliate partners
  (add to your partner program terms and onboarding email)
  
  All promotional content you create for [Product] must clearly disclose
  our commercial relationship. This is required by the FTC (US) and
  equivalent regulators in other jurisdictions.
  
  Acceptable disclosure formats:
  - #ad
  - #sponsored
  - #[ProductName]Partner
  - "I'm a paid partner of [Product]"
  - "This is a sponsored post"
  
  The disclosure must:
  - Appear before the main promotional content (not buried at the end)
  - Be clearly readable (not hidden in a sea of other hashtags)
  - Be present on every promotional post, not just your first one
  
  Failure to disclose can expose both you and [Product] to FTC action.