Who Must Disclose? Bloggers, Influencers, Brands, and Networks

The disclosure rules apply to anyone making a monetized recommendation — regardless of audience size — and increasingly to the brands and networks behind them.

The disclosure rules apply to anyone who makes a monetized recommendation to an audience. That is a wide net, and it is deliberately wide, because regulators focus on the substance of the relationship rather than on job titles or company size.

People and businesses covered

• Bloggers and content publishers who place affiliate links in articles, reviews, comparisons, and resource pages.
• Influencers and creators on Instagram, TikTok, YouTube, X, Twitch, Pinterest, and every other social platform.
• Review and coupon sites that earn commissions on outbound links to merchants.
• Email newsletter operators who monetize with affiliate links or sponsored placements.
• Podcasters reading affiliate offers or host-read ads.
• Comparison and “best of” sites ranking products they are paid to link to.
• Brands and advertisers, who share responsibility for ensuring their affiliates and endorsers disclose properly.
• Networks, agencies, and intermediaries, who under the 2023 FTC revision can also bear liability.

Size does not create an exemption

There is no follower threshold below which the rules stop applying. A hobbyist blog with a handful of affiliate links has the same disclosure obligation as a major publisher. Enforcement attention naturally concentrates on larger operators and repeat offenders, but the legal duty is identical.

The special position of brands

Advertisers cannot outsource away their responsibility. In both the US and UK, if a brand runs an affiliate program, it is expected to have reasonable measures in place — program terms, training, and monitoring — to ensure its affiliates disclose. UK guidance updated in 2025 warns brands that continuing to work with creators who repeatedly fail to label content creates legal risk for the brand itself.

Intermediaries and platforms

The 2023 revision of the FTC Endorsement Guides expanded the scope of potential liability to intermediaries such as advertising agencies, public-relations firms, and review brokers that participate in creating or disseminating deceptive endorsements. If your business sits anywhere in the chain between a seller and an audience, you should assume the rules are relevant to you.

Last reviewed July 2026. This page is general educational information, not legal or tax advice.