ftc-disclosure-spot-checker

1. The content to review — Ask the user to paste the caption, script, video description, or storyboard. Accept any format: full caption text, rough script, video outline, or a summary of what the post says and shows. For video content, both the spoken script and any on-screen text matter — disclosures must be in both for video formats.
2. Platform and format — Which platform (Instagram, TikTok, YouTube, Facebook, Pinterest, X/Twitter) and what format (feed post, Reel, Story, TikTok video, YouTube video, YouTube Short, carousel, live stream)? Platform and format determine specific disclosure placement rules.
3. Material connection type — What is the relationship between the creator and the brand? Identify which applies:
   • Paid sponsorship (cash compensation)
   • Free product / gifting (product sent at no cost)
   • Affiliate relationship (commission-based links or codes)
   • Employee or brand ambassador (ongoing contractual relationship)
   • Family or personal relationship with someone at the brand
   • Contest or sweepstakes prize
   • Early or exclusive access to a product
   • Any combination of the above
4. Brand-specific disclosure requirements — If not in the context file, ask: "Does your brand require specific disclosure language, hashtags, or partnership labels beyond the FTC minimum?" Many brands have their own compliance standards that exceed FTC requirements.
5. Content claims — Does the caption or script make any product performance, health, efficacy, or results claims? Claims trigger additional disclosure obligations — the FTC requires that endorsers only make claims they can substantiate with honest experience.

• "What brand is this sponsored content for?"
• "Is this a paid post, gifted product, affiliate link, or some other type of brand relationship?"
• "Which platform and format will this go on?"

1. Visible Without Effort (The Scroll Test) — A disclosure passes only if someone casually scrolling would see it without tapping, clicking, swiping, or expanding anything. If the disclosure sits below Instagram's "...more" fold, buried in a hashtag stack, or flashes on screen for one second in a 60-second video, it fails. The FTC's "clear and conspicuous" standard means visible to the average viewer in the average viewing context — not visible if you squint and pause the video.
2. Say What It Is, Not What It Sounds Like — "#ad" and "#sponsored" are the FTC-endorsed terms. "#partner," "#ambassador," "#collab," "#gifted," and "#brandpartner" are ambiguous — the average consumer may not understand these mean the creator was compensated. When in doubt, use the plainest language: "Ad," "Paid partnership with [Brand]," or "I received this product for free from [Brand]." Cleverness in disclosure language is a compliance risk, not a creative choice.
3. Every Format Gets Its Own Disclosure — A disclosure in the caption does not cover the video. A disclosure in the video does not cover the caption. A disclosure in one Story frame does not cover the next frame. Each piece of content a consumer might see in isolation needs its own disclosure. For video content, the disclosure must be spoken AND shown on screen. For multi-frame Stories, every frame that promotes the product needs a visible disclosure.
4. Gifted Is Not Free From Disclosure — Free product, early access, PR seeding, affiliate codes, and contest prizes all require disclosure. The FTC defines a "material connection" as anything that might affect the weight or credibility of the endorsement. If a consumer would care that the creator did not pay for the product, it must be disclosed. The only content exempt from disclosure is content about a product the creator purchased themselves with no brand relationship whatsoever.
5. The Brand Shares Liability — The FTC holds both the endorser and the sponsoring brand responsible for disclosure compliance. Brands cannot outsource compliance to creators and claim ignorance. Every brand team reviewing creator content before it goes live should be checking disclosures — this is not just the creator's problem.

• Disclosure must appear in the first line of the caption — before the "...more" fold
• Must not be buried in a hashtag block at the end
• Instagram's "Paid partnership with [Brand]" label should be enabled in addition to caption disclosure — the label alone may not satisfy FTC requirements
• For carousels, disclosure must appear on the first slide if it contains on-screen text

• On-screen text disclosure must be visible for the full duration or at minimum the first 3 seconds — not a quick flash
• Font size must be readable on a mobile screen (not tiny text in the corner)
• Disclosure must also appear in the caption, first line
• Audio disclosure (spoken) recommended in addition to text for accessibility
• Instagram's "Paid partnership" label should be enabled

• Every Story frame that promotes the product must include a visible disclosure
• The disclosure must be readable over the background — not obscured by busy visuals or placed in low-contrast areas
• Must not rely solely on the small "Paid partnership" header text at the top — supplement with in-frame text
• A disclosure in one frame does not carry over to subsequent frames

• On-screen text disclosure must be visible in the first 3 seconds and remain visible throughout, or be clearly stated verbally at the beginning
• Caption must include #ad or equivalent in the first line
• TikTok's "Branded Content" toggle must be enabled — TikTok actively detects undisclosed branded content and may suppress reach within 2-3 hours if not disclosed
• TikTok requires creators to enable the content disclosure setting before posting commercial content

• Verbal disclosure within the first 30 seconds of the video
• Written disclosure in the video description above the "Show more" fold
• YouTube's "Includes paid promotion" checkbox must be enabled in video settings
• For mid-roll sponsored segments, a verbal and visual disclosure at the start of the segment

• On-screen text disclosure visible for the full duration or first 3 seconds minimum
• Verbal disclosure recommended
• Description disclosure (first line)
• YouTube's "Includes paid promotion" checkbox enabled

• Disclosure in the first line of the post text
• Facebook's "Branded Content" tag enabled
• For video: verbal and on-screen disclosure

• Disclosure must be in the same language as the content
• Disclosure must be in the same medium as the endorsement (audio endorsement = audio disclosure; visual endorsement = visual disclosure)
• Disclosure must not require any user action to see (no tapping "more," no scrolling, no expanding)

• Do not approve "#partner" or "#collab" as sufficient disclosure. These are ambiguous. The FTC's own guidance says consumers may not understand them as indicating a paid relationship. Replace with "#ad" or "Sponsored."
• Do not accept a disclosure only at the end of the caption. The FTC's "clear and conspicuous" standard requires the disclosure to be where consumers will see it — not where they have to scroll to find it. First line of caption, first seconds of video.
• Do not assume the platform label handles everything. Instagram's "Paid partnership" header, YouTube's "Includes paid promotion" banner, and TikTok's branded content toggle are good but not enough on their own. Always require in-content disclosure too.
• Do not skip the claims check. A perfectly disclosed post that makes false health claims is still an FTC violation. Disclosure and claim substantiation are separate requirements.
• Do not treat gifted content as exempt. Free product is a material connection. Period. It requires disclosure even if the brand did not explicitly ask for a post.

omg you guys this serum literally changed my skin in 2 weeks!! the vitamin C formula is insane and it cleared my dark spots completely. if you struggle with hyperpigmentation you NEED this. link in bio! Thanks to @GlowBrand for sending this over #beauty #skincare #glowup #partner #gifted

1. No clear disclosure — "#partner" and "#gifted" are ambiguous (Check 1, CRITICAL)
2. Disclosure buried at end of caption in hashtag stack (Check 2, CRITICAL)
3. "#gifted" contradicts a paid sponsorship — misleading connection type (Check 3, MODERATE)
4. "literally changed my skin in 2 weeks" and "cleared my dark spots completely" are health efficacy claims that need substantiation (Check 4, MODERATE)
5. No mention of enabling Instagram's Paid Partnership label (Check 5, MODERATE)

#ad | Paid partnership with @GlowBrand

omg you guys this serum has made a real difference for my skin! the vitamin C formula is so good and I've noticed my dark spots fading. if you struggle with hyperpigmentation check this out. link in bio! #beauty #skincare #glowup

• SMB brands (solo marketer, small team) — Deliver a short, direct pass/fail verdict with the exact fixes needed. These teams are often running their first creator campaigns and may not know FTC rules well. Include a one-sentence explanation of why each fix matters. Keep the output under 400 words so they can act on it immediately. They need a checklist they can send straight to the creator.
• Mid-Market brands (influencer team) — Deliver the full audit with all five checks. These teams review 20-200+ creator submissions per campaign and need a standardized compliance process. Include the platform-specific details and claims review — mid-market teams are building scalable compliance workflows and need the full picture.
• Enterprise brands and agencies — Deliver the full audit plus a risk assessment for each finding. Enterprise teams and agencies need the output formatted for legal review and client reporting. Flag regulated-category issues prominently. Include the specific FTC rule or guidance that each finding references so legal can verify independently.

• CRITICAL — Missing disclosure entirely, disclosure not visible, or unsubstantiated claims. Must fix before posting.
• MODERATE — Ambiguous disclosure language, suboptimal placement, or missing platform tool. Should fix before posting.
• LOW — Minor improvement opportunity that would strengthen compliance but is not required. Fix if time allows.

• In-content disclosure visible without any user action
• Disclosure in first line of caption (text platforms) or first 3 seconds (video)
• Platform disclosure tool enabled ([specific tool for the platform])
• Disclosure language is unambiguous (#ad, Sponsored, or Paid partnership)
• Disclosure matches the connection type (paid, gifted, affiliate, etc.)
• All product claims reflect genuine experience and are substantiated
• Disclosure in same language as content

1. Every finding cites the specific content that triggered it — No vague flags like "disclosure could be better." Quote the problematic text and explain what is wrong with it.
2. Every fix is copy-paste ready — The corrected caption or disclosure language is exact, not a description of what to write. The user should be able to copy the fix and send it to the creator.
3. Severity ratings are calibrated to actual FTC risk — A missing disclosure is CRITICAL, not MODERATE. An ambiguous hashtag is MODERATE, not CRITICAL. Do not inflate or deflate severity.
4. The corrected version preserves the creator's voice — Compliance fixes should modify as little of the original content as possible. Do not rewrite the creator's caption — insert or move the disclosure and leave everything else intact.
5. A compliance manager reviewing 30 creator posts in a batch could use this output to approve or send back each post in under 60 seconds — The verdict is clear, the fixes are specific, and the corrected version is ready to send.

• If you need to check creator content against the full campaign brief (messaging, format, visual requirements, and disclosures), see content-to-brief-compliance-checker.
• If you need to format compliance feedback into a constructive revision request to send to the creator, see content-approval-feedback-formatter.
• If you need to screen a creator's content history for brand safety risks beyond just disclosure, see brand-safety-screen.
• If you need to build a campaign brief that includes proper disclosure instructions for creators, see campaign-brief-generator or content-brief-builder.
• If the brand context is missing or incomplete, see brand-context.