Disclosure Checklist

Minutes

Before publishing sponsored, affiliated, incentivized, or endorsed content, check that every material connection between the speaker and the brand or cause is disclosed clearly, conspicuously, in plain language, and in the same place and format as the claim it qualifies.

How to do it

  1. 1List every material connection: payment, free or discounted products, affiliate commissions, employment, ownership, family ties, sweepstakes entries, early access, or any other benefit that might affect how an audience weighs the endorsement. If the audience would want to know, it is material.
  2. 2Put the disclosure where it cannot be missed: within the content itself and with the claim, not only in a profile, behind a "more" link, at the end of a long caption, or buried in a run of hashtags. In video, say it and show it. On a live stream, repeat it.
  3. 3Use words ordinary people understand: "ad", "advertisement", "sponsored", "paid partnership with", "I was given this free". Avoid ambiguous tags such as "sp", "collab", "ambassador", or "thanks to" standing alone. Do not rely solely on a platform's built-in disclosure tool if it is easy to overlook.
  4. 4Match the language and the medium of the endorsement, and make sure the disclosure is visible on the devices the audience actually uses.
  5. 5Check the content as well as the label. Endorsers should have actually used the product, should not make claims the advertiser could not substantiate, and should reflect honest opinion. Disclosed or not, a false claim is still deceptive.
  6. 6Do not procure, suppress, or reward reviews selectively. Disclose incentives for reviews, never write or buy fake ones, and do not gate review requests so that only happy customers are asked.
  7. 7If you are the brand, give endorsers written guidance, monitor what they post, and fix or end relationships with those who do not comply. Responsibility is shared.

When to use it

  • •You run influencer, affiliate, ambassador, employee-advocacy, or review-generation programs.
  • •You create content and have received anything of value from a brand or cause you mention.
  • •You publish native advertising or branded content alongside editorial material.
  • •A political or advocacy campaign is paying or coordinating people to post as ordinary supporters.

Counters

Undisclosed SponsorshipNative Advertising DeceptionInfluencer SeedingFake ReviewsTestimonial EngineeringAstroturf BotsAstroturfingSockpuppetingProduct Placement PsychologyFront GroupsInformation LaunderingTestimonial PropagandaPlain Folks AppealFake Verification BadgeCoordinated Inauthentic Behavior

Evidence and how strong it is

The legal backbone in the United States is the FTC's Guides Concerning the Use of Endorsements and Testimonials in Advertising (16 CFR Part 255), substantially revised in 2023, together with the agency's plain-language guidance for influencers and its 2024 rule on fake consumer reviews and testimonials. The Guides require clear and conspicuous disclosure of material connections that the audience would not expect, and state that advertisers as well as endorsers can be liable. The behavioral rationale is the Persuasion Knowledge Model: people evaluate a message differently once they recognize it as a persuasion attempt (Friestad & Wright 1994), so hiding the commercial relationship deprives them of information they would use. Experimental work shows that whether disclosures work depends heavily on execution; Wojdynski and Evans (2016) found that only a small minority of readers recognized native advertising as advertising at all, and that wording such as "advertising" or "sponsored" and placement in the middle or bottom of the page improved recognition compared with vaguer labels at the top. Evidence strength: clear regulatory requirements in the US and similar rules in many other countries; good experimental evidence that disclosure design matters; disclosures reduce deception without eliminating it.

Cautions
  • This is a summary for orientation, not legal advice. The FTC Guides are US-specific; the UK (ASA/CMA), the EU, Canada, Australia, India, and others have their own rules, and platform policies add further requirements. Political advertising is regulated separately. Get legal review for anything substantial.
  • Disclosure does not cure a deceptive claim. A clearly labeled advertisement that misleads about the product is still misleading.
  • A disclosure that is technically present but designed to be missed (tiny, fleeting, low contrast, or lost among hashtags) is treated by regulators as no disclosure.
  • Over-disclosure in boilerplate trains audiences to ignore all of it. Keep disclosures short, specific, and close to the claim.
  1. US Federal Trade Commission (2023). Guides Concerning the Use of Endorsements and Testimonials in Advertising (16 CFR Part 255). Federal Register / Code of Federal Regulations
    The requirement to disclose material connections clearly and conspicuously, the standards for endorsements and consumer reviews, and the shared liability of advertisers and endorsers.
  2. US Federal Trade Commission (2019). Disclosures 101 for Social Media Influencers. ftc.gov
    Plain-language guidance on when and how to disclose, including placement, wording, and the inadequacy of vague tags.
  3. Wojdynski, B. W., & Evans, N. J. (2016). Going native: Effects of disclosure position and language on the recognition and evaluation of online native advertising. Journal of Advertising, 45(2), 157-168
    Experimental evidence that few readers recognize native advertising and that disclosure wording and position significantly affect recognition.
  4. Friestad, M., & Wright, P. (1994). The Persuasion Knowledge Model: How people cope with persuasion attempts. Journal of Consumer Research, 21(1), 1-31
    The theory that recognizing a message as a persuasion attempt changes how people process it, the behavioral rationale for disclosure.
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