Home / Answers / Rights, disclosure and AI
Do UGC ads need to be disclosed?
Yes, when there's a paid relationship. Ads run from your ad account are already labelled as sponsored. If a creator posts about your product organically in exchange for payment or free product, they must clearly disclose it, and platforms provide branded-content or paid-partnership labels for this.
When disclosure is needed
The FTC's endorsement guidance says that if there's a connection between an endorser and a brand that viewers wouldn't expect, such as payment, free product, or being an employee or relative, it should be disclosed clearly and conspicuously.
| Situation | What to do |
|---|---|
| Ad run from your ad account | Platform labels it "Sponsored"; keep claims honest |
| Creator posts on their own account for pay or free product | Clear disclosure in the post plus the platform's paid-partnership tool |
| Ad run from a creator's handle | Use Meta partnership ads or TikTok Spark Ads, which show the relationship |
| Employee or family member on camera | Make the connection clear |
Built-in tools may not be enough
The FTC's 2023 update to its Endorsement Guides noted that a platform's built-in disclosure tool might not, on its own, be an adequate disclosure. Clear words in the video or caption, like "paid partnership" or "ad", help.
AI content is a separate question
Labelling a video as an ad doesn't cover AI labelling. Platforms such as TikTok have separate rules for realistic AI-generated content.
General information, not legal advice.
Our own rules at ScrollStop Labs: AI presenters never pose as real customers, claims come from the label, and AI labels stay on.
Sources
- FTC: FTC's Endorsement Guides, What People Are Asking
- Meta Business Help Center: About partnership ads
- FTC: Updated Endorsement Guides announcement (Jun 29 2023)