Your FTC Cheat Sheet for Affiliate and Paid Influencer Campaigns


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Written by Ellen Borza

Influencer marketing has exploded in recent years, especially in the fashion industry. You’ve likely seen examples of this type of marketing when you’ve come across an Instagram photo or tweet with hashtags like #sponsored or #ad. You may have even read a post on a blog that has a disclaimer like, “This post is sponsored by… All opinions are my own.”

2017 is expected to be an even bigger year for influencer marketing, so don’t be surprised if you see more disclaimers like the ones mentioned above. If you’re a fashion brand or emerging communicator looking to make sure your influencer outreach is according to industry best practices, it’s important to understand FTC guidelines and Google’s rules for disclosure in advertising.

Read on for everything you need to know about partnering with influencers and maintaining transparency with brand consumers.

Disclosure 101

FTC guidelines are intended to create transparency between brand and consumer and prevent deceptive advertising. Google’s stance is very much the same as the FTC’s. It wants you to disclose paid relationships. Google urges users to add the directive “rel= nofollow” to links that are paid to prevent manipulation of search engine rankings. This directive tells search engines not to follow the link.

Regarding affiliate links, Google knows how to handle affiliate links from large networks and has previously said that while not required, you can add a nofollow directive to affiliate links if you want.

If a blogger naturally links to your brand simply because they want to share how much they love the sweater they just bought, a dofollow link is acceptable. Your brand doesn’t have a relationship with this blogger, and you never directly asked for the link.

On the other hand, you might decide that you want to work with them because this blogger already loves your brand. Any content that blogger creates on your brand’s behalf is considered sponsored.

If you send someone a free product or provide monetary compensation in exchange for a review or post on a blog, the link needs to be a nofollow link. Yes, even free product is considered “paid” to Google and the FTC.

Here is an easy way to decide if you need to ask for influencers to use nofollow links:

  • Link= endorsement
  • Nofollow link= paid endorsement

You can, and should, use links when working with influencers. After all, the hope is that their followers want to buy your products! A nofollow link is still valuable and capable of bringing relevant users to your site. It’s simply telling search engines not to pass PageRank those links.

Social Media Requirements

As your influencer marketing efforts expand, you’ll likely be working with influencers across different platforms. For bloggers, you must require that any links to your brand are nofollow links. It does not matter what platform the blog is on. Always include nofollow links.

YouTube is unique in that there is only one dofollow link, and it’s the custom link included in the channel art. All other links are nofollow. Nonetheless, you should still encourage vloggers to add a disclaimer in the video description to indicate your relationship like, “This post is sponsored by [insert brand here]”.

If you are running a campaign on a social platform, any influencer posts published as part of the campaign need to indicate that the post is sponsored. On social platforms, hashtags like #sponsored or #ad are acceptable. There is debate about whether or not #sp is proper disclosure. While this is becoming increasingly common, The Fashion Law suggests #sp is not clear enough. Again, it should be clear to consumers when the post is sponsored. Frequently you’ll see these types of posts on Instagram, especially in the fashion industry.

Below is an example from Ashley Robertson (The Teacher Diva). Her Instagram post clearly states her relationship with Sole Society with hashtags like #SSPartner and #ad. If your brand develops Instagram influencer campaigns, this post is a good example to follow for clear disclosure.


Finally, remember that if an influencer doesn’t include proper disclosure, your brand will be at fault. Here’s how you can be clear with influencers about proper disclosure.

Make disclosure a campaign discussion point

Now that you know how to be transparent, how can you ensure that FTC guidelines are maintained while working with influencers?

First, look for influencers who are honest with their followers. When you find an influencer you want to reach out to, look for examples of previous campaigns they have done. Are promotional Instagram posts clearly marked as sponsored? Does the blogger have a disclosure statement at the beginning or end of the post? It is easy to tell when content is sponsored but doesn’t explicitly say so.

Once you reach out, set expectations with influencers from the beginning. Whether you provide monetary compensation or send product, clearly state that links must be nofollow. More than likely, they’ll want to be honest with their followers, too. If you’re sending several products, you can create tracking URLs that already have the “rel= nofollow” so you know the directive is included. Again, be clear throughout your communication about what should be included in their content.

Feel free to offer examples of disclosure statements to include in the post. They don’t have to be uptight, but they do need to be obvious. Here are two suggestions:

  • “Thanks to [brand name] for partnering with me on this post!”
  • “I received compensation from [brand name] in exchange for this post. Thanks for supporting the brands that make [blog/channel name] possible!”

Influencer marketing has experienced exponential growth recently. As a result, the need to be clear with consumers is extremely important. Focus on maintaining transparency at all times. If the content you develop with influencers is useful and authentic, advertising disclosures won’t overshadow it.

For a comprehensive training on developing Instagram collaborations with influencers including sample project briefs and contracts, sign up for the PR Couture course Instappable!

About Ellen 

Ellen Borza is a Senior Online PR Specialist at Web Talent Marketing, a full-service digital marketing agency located in Lancaster, PA. Ellen earned a B.A. in communications and a B.S. in psychology from the University of Pittsburgh. When Ellen isn’t conducting outreach for her clients, she loves reading and writing about the latest digital marketing trends, especially as they relate to fashion. In her free time, she authors her own fashion and lifestyle blog.