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·3 min read·compliance, ftc, influencer-marketing

FTC Disclosure Rules for Influencer Campaigns: A 2026 Checklist

What brands and agencies need to check on every sponsored video — clear-and-conspicuous disclosures, where they belong, and the mistakes that get flagged.

If your brand pays, gifts, or otherwise incentivizes a creator, the FTC expects a clear and conspicuous disclosure of that relationship. The rules aren't new, but enforcement — and platform-specific nuance — keeps catching brands off guard. Here's the practical checklist we apply to every video.

The one rule underneath all the others

A disclosure has to be hard to miss and easy to understand for an ordinary viewer. That's the "clear and conspicuous" standard, and it's judged from the viewer's perspective, not yours. Buried, blink-and-you-miss-it, or jargon-y disclosures don't count — even if they're technically present.

The checklist

  1. It exists at all. A material connection between the brand and creator must be disclosed. "Material" is broad: payment, free product, discount codes, affiliate commission, family/employee relationships.
  2. It's placed where people actually see it. On video, that means on-screen and in the audio, near the start — not only in the description, not only in a caption that's cut off, not only after 90 seconds.
  3. It's in plain language. "Paid partnership," "Sponsored," "#ad," or "Thanks to [brand] for sponsoring this video" all work. Vague tags like "#sp," "#collab," "#ambassador," or "#thanks" generally don't.
  4. It stays up long enough. A disclosure flashed for half a second isn't clear and conspicuous. If it's on screen, it needs to be legible for a real beat.
  5. It matches the platform. Platform tools (e.g. "Paid partnership" labels) are a good addition but not a substitute for a creator's own disclosure.
  6. It survives the format. Sound-off viewing, Stories, Shorts, and fast cuts all break disclosures. If the claim only works with audio on, it fails for the muted majority.

The most common failure we see isn't a missing disclosure — it's one that's present but not clear and conspicuous: shown too briefly, too small, or only in the caption. It passes a human skim and fails the standard.

Where this quietly goes wrong at scale

For a single video, a careful reviewer can catch all of this. The problem is volume. A campaign with 40 creators and 3 cuts each is 120 videos, each needing a frame-by-frame check for a disclosure that might appear on screen at 0:02 for 0.4 seconds. That's exactly the kind of check that gets skipped when a launch is behind schedule — and it's exactly the kind that shows up later.

What "good" looks like

  • Spoken and on-screen disclosure within the first few seconds.
  • Plain wording ("paid partnership with [brand]").
  • Legible for a couple of seconds, readable sound-off.
  • Consistent across every cut and platform.

That's checkable. In fact, it's checkable automatically — which is the whole reason we built CherryBowl.

Check a video against these rules in seconds

Upload a creator video and CherryBowl flags missing or too-brief disclosures — with the exact timestamp — alongside your other brand rules.

See the AI review a video

Or join the early-access waitlist.

This is general information, not legal advice. For specifics, consult the FTC's Endorsement Guides and your counsel.