What is the FTC rule on incentivized reviews?

The FTC's Endorsement Guides (16 CFR Part 255) require that any "material connection" between an endorser and a brand be disclosed. A material connection is anything of value — money, a free product, a discount, store credit, even a sweepstakes entry — that could reasonably affect what the endorser says.

The disclosure must be: • Clear and conspicuous — visible without scrolling, not buried in hashtag soup • Unambiguous — "#ad" or "#sponsored" works; "#thanks @brand" doesn't • Close to the endorsement — same post, same story, not in a bio link • In the same language as the endorsement

The 2023 update made one thing especially clear: brands are accountable for their endorsers' disclosures. "I told them to disclose" isn't a defense. You need to monitor, train, and have a paper trail.

Non-compliance penalties have escalated. The FTC's 2024 Final Rule on fake reviews allows civil penalties up to $51,744 per violation. Fashion Nova paid $4.2M in 2022 for suppressing negative reviews. Sunday Riley paid $0 to the FTC but had to operate under a consent decree banning misleading reviews for 20 years.

What compliance looks like in practice: every campaign brief tells the customer exactly which disclosure to use. The platform validates submissions before approving. There's a paper trail (timestamped submission, platform of post, exact disclosure used) you can produce if asked. Social Perks does all three by default — there's no "compliance mode" because compliance is the only mode.