FTC Guidelines for Health Leaders: What You Must Disclose

Sponsored content is everywhere on social media, and health is no exception. But when you are a Health Leader, your recommendations can carry the same trust as the recommendations of a friend. This is exactly why regulators pay closer attention to health content than to almost anything else online.

Here is what the Federal Trade Commission (FTC) expects of you, updated for the current rules.

Two agencies watch health content — this is the first

Two federal agencies pay attention to what health creators post. The FTC cares about who is in the room (the relationships behind your post, like if a company asked you to post their product). The Food and Drug Administration (FDA) cares about what you say, like the claims your post makes about a treatment. This article covers the FTC. For the FDA’s rules on claims, fair balance, and staying “on label,” read our companion guide.^1,2

One thing to keep in mind as you read: you can follow one set of rules perfectly and still break the other. A flawlessly disclosed post can still make a claim that is not allowed. Disclosure is not a shield. Disclosure just tells your audience who is in the room, and it does nothing to make an untrue statement acceptable.

What are the FTC Endorsement Guides?

The FTC is the United States consumer protection agency, and its Endorsement Guides are the rules for anyone who recommends a product — celebrities, influencers, patients, caregivers, and healthcare professionals alike. Nothing in that definition turns on audience size: what matters is whether people are likely to believe the message reflects your own opinions and experience rather than the advertiser’s.

The Guides define an endorsement as any promotional message that people are likely to believe reflects the opinions or experiences of someone other than the advertiser. That definition is broad on purpose: it covers what you say, what you demonstrate, and even a social media tag.¹

They were last revised in 2019 with influencer guidance, then rewritten for the creator economy in 2023.³ The FTC also publishes plain-language guidance written for creators specifically.⁴ The core idea has never changed: if a brand gives you something to talk about its product, your audience deserves to know.

When you must disclose

You have what the FTC calls a material connection any time there is a link between you and the seller that might affect how much weight or credibility your audience gives your endorsement. The Guides name business and family relationships, payments, free or discounted products, early access, and even the chance of a prize.¹ In practice, that means disclosing when:

• You were paid to post, or you are in a paid partnership or ambassador program.
• You received the product free or at a discount to mention it — even if the brand never specified which post.
• You earn a commission through an affiliate link or discount code.
• A brand covered your travel, hotel, or conference registration. The FTC says plainly that you should disclose free travel and accommodations, because it could affect how much weight readers give your thoughts.⁶
• You work for, do business with, or are related to someone at the company.

Do not assume your followers already know about a relationship, and do not assume an honest opinion exempts you.⁴ If the connection could affect how someone weighs your words, disclose it.

What changed in 2023: the bar got higher

The 2023 rewrite of the Endorsement Guides raised expectations in several ways that matter for health leaders. The FTC named six changes, including a new definition of “clear and conspicuous,” an expanded definition of endorsements that now covers fake reviews, virtual influencers and social media tags, and a clearer account of who can be held liable.³

For creators, three land hardest:

1. Tags count. Tagging a brand you are wearing or using is itself an endorsement.⁶ Tagging is not a disclosure, though — it does not tell anyone about a relationship.
2. A platform’s built-in tool might not be enough. The 2023 revision says so directly.³
3. Endorsers can be liable. The Guides state that endorsers may be liable for representations they know or should know are deceptive, for claiming to use a product they do not, and for failing to disclose an unexpected material connection.¹

In practice the FTC says its focus “usually will be on advertisers or their ad agencies,” but action against an individual endorser “might be appropriate in certain circumstances — for example, if the endorser hasn’t made required disclosures despite warnings.”⁶

How to disclose the right way

Put it up front

Place the disclosure where the endorsement is. The FTC warns that disclosures are likely to be missed if they appear only on a profile page, at the end of a post, or anywhere someone has to click “more” — and says not to mix a disclosure into a group of hashtags or links.⁴

Match the format

Superimpose it over the image with enough time to be read, and put it in the video rather than only the description, since many people watch without sound. For live content, repeat it periodically so people who join partway through still see it.⁴ The disclosure must be in all formats.

Use simple, clear language

“Paid partnership with [Brand],” “advertisement,” “ad,” or “Thanks to [Brand] for the free product” all work. The FTC specifically tells creators to avoid vague terms like “sp,” “spon,” or “collab,” and stand-alone words like “thanks” or “ambassador.”⁴

Use platform tools as an addition, not a substitute

Meta or TikTok’s “Paid partnership” label is helpful, but the FTC says the ultimate responsibility for a clear and conspicuous disclosure rests with the influencer and the brand, not the platform.⁶

Match the language of your post

If you post in Spanish, disclose in Spanish.⁴

Make it readable

Contrasting colors, a font people can actually read, and on screen long enough to be read.⁴

Four examples you will recognize

None of these creators set out to mislead anyone. That is exactly the point — most disclosure problems do not come from bad intent. They come from posts that do not feel like ads to the person making them.

1. The discount code

Sarah, a creator living with endometriosis, has taken the same magnesium supplement for over a year and talks about it constantly — because she loves it. Eventually the brand notices and offers her a creator code: her followers save 15 percent, and she earns a small commission on every order. One morning she films her real routine — coffee, stretching, supplement — and captions it “obsessed with my mornings lately, use code SARAH15 to save.” No #ad, no mention of the commission. In her mind, this is not a sponsored post. Nobody paid her to make it, nobody approved it, and every word is true.

The problem: the moment that code started earning her money, she had a financial connection to the brand — and that is exactly the kind of link the Guides say might affect how much weight her audience gives her enthusiasm.¹

The fix: one honest line at the top of the caption — “#ad, I earn a commission when you use my code” — and a quick mention in the video itself. Her genuine love for the product does not change. Her audience’s ability to weigh it fairly does.

2. The bio disclosure

A health leader juggling several ongoing partnerships decides to get organized. He adds a line to his profile, lists his partners in his bio, and considers the matter handled once and for all. Efficient, transparent, done.

The problem: almost nobody who sees his posts ever visits his bio. His content reaches people through feeds, shares, and explore pages — each post arrives alone, stripped of any context his profile provides. The FTC is explicit that a disclosure on a profile page is likely to be missed, and that one disclosure in one place cannot cover posts people see on their own.^4,6

The fix: every sponsored post carries its own disclosure, up front, every time. The bio line is fine as a supplement — it just cannot do the job alone.

3. The free PR box

A skincare-loving psoriasis creator comes home to a package she never ordered: a full PR box from a brand, with a note saying “no strings attached.” She films an unboxing because the packaging is gorgeous and her followers love this kind of video. She skips the disclosure, reasoning that nobody asked her to post and nobody is paying her.

Where the line actually falls, and it is finer than most people think. The FTC’s own FAQ says that if you receive an unsolicited product from a brand you have no relationship with, and nothing was given to have you mention it, disclosure is not required.6 But that is a narrower exception than it sounds.

If you are on a brand’s PR or creator list, if the product came because of an existing relationship, or if it was sent in the hope you would post, you have a material connection and it needs disclosing.^1,6

The fix: know which situation you are actually in — and when it is not obvious, say the sentence anyway. “[Brand] sent me this for free” costs nothing, and it keeps every nice thing you say afterward believable.

4. The conference trip

A caregiver is invited to a pharma-sponsored patient summit — flights covered, hotel covered, meals covered. Nobody pays her to post, and nobody asks her to. But one session on an emerging therapy genuinely moves her, and on the flight home she writes a thoughtful thread about what she learned. Her takeaways are honest, even critical in places. She never mentions who covered the trip.

The problem: the FTC says you should disclose free travel and accommodations, precisely because they could affect how much weight readers give your thoughts about a product.6 Her followers are reading her enthusiasm for a session at an event a company selected her for, flew her to, and shaped the agenda of — without knowing any of that. This one comes up a lot for health leaders. Summits, advisory boards, and brand-hosted events are among the most common ways companies work with our community, and covered travel is one of the most commonly forgotten disclosures.

The fix: open the thread with it. “I attended [Summit] as a guest of [Company], which covered my travel and hotel. These takeaways are my own.” Her honest perspective stays fully hers — the audience just gets the whole picture.

Health claims carry an extra burden

Disclosure is not the only thing the FTC watches in health content. Its health products guidance says claims about health benefits or safety need support in the form of competent and reliable scientific evidence, and that for health benefit claims, randomized controlled trials are generally what experts would require.⁷

Two parts of that guidance speak directly to creators. Advertisers must be able to back up the implied claim that a product will work for buyers the way it worked for the person endorsing it. And testimonials reporting results more dramatic than people can generally expect are likely to be deceptive.⁷ Your experience is yours to share — but a sponsored post cannot let it stand in for evidence.

What happens if you do not disclose

The FTC can seek civil penalties, which as of 2025 run to $53,088 per violation for the conduct covered by Sections 5(l) and 5(m) of the FTC Act.8 Health products have been an enforcement focus for a long time: the agency reports settling or adjudicating more than 200 cases involving false or misleading advertising claims about health products since 1998.⁷

For health leaders, though, the bigger risk is trust. Your community weighs your words like a friend’s, and an undisclosed partnership breaks that faith in a way no penalty matches.

The bottom line

When in doubt, disclose. Transparency is not a tax on partnerships — it is what makes your recommendation worth something in the first place.

Want to go deeper? Review the FTC’s Disclosures 101 for Social Media Influencers, enroll in the Patient Leader Certification Program (Module 3 covers these rules in depth), or pursue the Institute for Responsible Influence Certification to signal to brands that you know the rules before you ever get on a call.

This article is educational information, not legal advice.