# Influencer Disclosure Policy Template (One Page)

Source: https://www.seedinfluencers.com/blog/influencer-disclosure-policy-template
Published: 2026-09-25

A one-page policy covering the FTC's three asks: tell creators to disclose, check their posts, act on misses. Copy-paste template, about an hour to set up.

An influencer disclosure policy is a one-page document that covers the three things the FTC expects from brands that work with creators: tell them to disclose, check that they did, and act when they didn't. For a brand gifting 10 to 200 creators a month, it takes about an hour to set up and 30 to 60 minutes a month to run. The copy-paste template is below.

This is a plain-English guide, not legal advice. The rules are in [FTC disclosure rules for gifted products](https://www.seedinfluencers.com/blog/ftc-disclosure-rules-for-gifted-products). This post turns them into a process you can actually run. Pay an advertising lawyer to review your policy if you run a paid ambassador program at volume, sell supplements or other products with health claims, or have received an FTC letter.

## Why a small gifting brand needs one at all

Because the FTC says the brand shares the responsibility. The Endorsement Guides (16 CFR 255.1(d)) say advertisers should do three things:

1. Give endorsers guidance on disclosing material connections.
2. Monitor their compliance.
3. Take action to fix non-compliance and prevent it happening again.

A free product is a material connection even if you never asked for a post. Section 255.5 says so, and its own example of a brand sending an influencer a free product says the brand should tell them to disclose "at the time it provides" the product and "have reasonable procedures in place to monitor."

The rule calls this "not a safe harbor," but says good-faith guidance, monitoring and remedial action reduce "an advertiser's odds of facing a Commission enforcement action." The FTC's endorsement FAQ also says it is "unrealistic" to expect you to know every statement creators make. It expects a "reasonable effort," and says the program's scope "depends on the risk." For a brand gifting candles or socks, reasonable means one page, not a compliance department.

There's a practical reason too. When a creator posts without #ad, the policy tells you exactly what to do, so you're not working it out on the spot. The step-by-step version is in [a creator posted without disclosure: what to do](https://www.seedinfluencers.com/blog/creator-posted-without-disclosure-what-to-do).

## The five parts of the policy

### 1. The exact wording creators must use

Don't write "please disclose appropriately." Give creators the words. Vague instructions produce vague disclosures, and the FTC names several that don't work: "sp," "spon," "collab," a bare "thanks," and "ambassador" without context. It also says "Gifted" on its own, without the brand name, is likely to be ambiguous.

| Where | What to require |
| --- | --- |
| Instagram feed, Reels, TikTok captions | "Gifted by @brand" or "#ad" in the first line, visible without tapping "more" |
| Instagram Stories, Snapchat | Text on the image or video itself, not only in a tag |
| Video (TikTok, Reels, YouTube) | Said out loud or on screen in the video, plus the caption |
| Livestreams | Said out loud, and repeated during the stream |
| Platform "paid partnership" label | Encouraged, but in addition to the wording above, not instead of it |
| UK audiences | "Ad" at the start. The CMA treats #gifted as ambiguous, even for no-strings gifts |

Every row comes from the FTC's _Disclosures 101 for Social Media Influencers_, except the UK row, which comes from the CMA's guidance for content creators. The FTC also says the disclosure should be in the same language as the post, so a Spanish-language post gets a Spanish disclosure.

### 2. Where the creator agrees to it

The FTC wants the instruction given when you hand over the product, not after the post goes up. Put the line in three places and it can't be missed:

- The outreach DM or email where you offer the gift.
- The gift form or order confirmation, as a required checkbox. If you use Seed, the gift form can show your terms with a required checkbox and records when each creator accepted, so the proof is attached to the order.
- Your written agreement, if you use one. The [influencer agreement guide](https://www.seedinfluencers.com/blog/influencer-agreement-contract) has clause wording.

### 3. How often you check

The FTC's FAQ says to "periodically search for what members of your network are saying." It doesn't give a number, so set one you'll actually keep:

| Gifts per month | What to check | Time per month |
| --- | --- | --- |
| 10 to 25 | Every post, within a few days of going live | 15 to 30 minutes |
| 25 to 100 | Every first post from a new creator, plus about 1 in 5 repeat creators | 30 to 60 minutes |
| 100 to 200+ | Every first post, a monthly sample of repeat creators, and every post you plan to reshare or run as an ad | 1 to 2 hours |

You're already looking at these posts to see whether creators posted at all. Add a five-second disclosure check to that step. Check posts on the platforms you actually track. The FTC says you don't need to monitor platforms you don't otherwise watch, but if you learn about a problem on one, "don't ignore it."

### 4. The record log

A spreadsheet is enough. One row per post checked:

- Creator handle, platform, post URL, date posted
- Gift order number and date the disclosure instruction was given
- Disclosure present? (yes / no / weak)
- Action taken and date (none / fix requested / fixed / stopped gifting)
- Screenshot link

If you ever get a warning letter, this log shows you had a program and ran it. Keep it in the same place as your [creator records](https://www.seedinfluencers.com/blog/building-a-creator-crm-in-shopify) so a creator's history is in one place.

### 5. The escalation rule

Decide this in advance so every miss gets the same response:

- **Miss found:** screenshot, then a friendly fix request within one business day.
- **Not fixed in 48 hours:** second written request, and pause any reshares or ad spend on that post.
- **Ignored twice, refused, or repeated after being told:** no further gifts. Note it in the creator record.
- **Health, cure, or earnings claim:** ask for the claim to be removed the same day, regardless of disclosure.

### Get the disclosure agreement at the moment of gifting

Seed's gift form can require creators to accept your terms before the $0 order lands in Shopify.

[Install on Shopify](https://apps.shopify.com/influencer-form)

## The copy-paste template

Replace the brackets and save it where your team can find it. Edit the cadence to match your volume.

> **[Brand] Creator Disclosure Policy**  
> Owner: [name]. Last reviewed: [date].**1. Scope.** Applies to every creator who receives free or discounted product, payment, affiliate commission, or any other benefit from [Brand], whether or not a post is required.**2. Required disclosure.** Creators must clearly disclose the relationship in every post featuring [Brand] products. Approved wording: "Gifted by @[brand]", "Thanks @[brand] for the free product", or "#ad". It goes in the first line of the caption, visible without tapping "more". In video, it is also said out loud or shown on screen. On Stories, it is text on the image. UK creators use "Ad". Platform partnership labels are used in addition to this wording, never instead of it. Not acceptable: "sp", "spon", "collab", "thanks @[brand]" alone, "#gifted" without the brand name.**3. When creators are told.** Before the product ships: in the outreach message, on the gift form (required checkbox), and in the written agreement where one is used.**4. Claims.** Creators may share honest opinions, including negative ones. They may not claim [Brand] products treat, cure, or prevent any condition, or make claims we cannot back up. [Add product-specific do-not-say list.]**5. Monitoring.** [Owner] checks [every first post from a new creator within 3 days of going live, plus [X]% of repeat creators monthly], and every post before we reshare it or put ad spend behind it.**6. Records.** Every check is logged in [sheet/CRM] with the post URL, date, disclosure status, screenshot, and action taken. Records are kept for [3] years.**7. Escalation.** Missing or weak disclosure: fix request within 1 business day. Not fixed in 48 hours: second request, pause reshares and ads. Ignored twice, refused, or repeated: no further gifts. Any health, cure, or earnings claim: removal requested the same day.**8. Reviews.** We never make a gift or any other benefit conditional on a positive review or rating.**9. Review of this policy.** Every [6] months, and whenever we start paying creators or enter a new country.

Two notes on the template. Clause 8 isn't optional. If you also ask gifted creators to leave a review on your product page or Amazon, the FTC's Consumer Reviews and Testimonials Rule (16 CFR 465.4, in effect since October 2024) bans giving incentives "conditioned expressly or by implication" on a review expressing a particular sentiment. That is a binding rule, and breaking a rule is one of the situations where the FTC can seek civil penalties (up to $53,088 per violation at the current adjusted amount). Clause 4 is where supplement, skincare and CBD brands need the most detail, because a creator's health claim is a far bigger problem than a missing hashtag.

The three-year retention period in clause 6 is a sensible default, not a legal requirement we could find in the Guides. Adjust it to whatever your accountant or lawyer prefers.

## What this costs versus what it saves

Setup: about an hour to fill in the template, add the line to your DM template and brief, and turn on a terms checkbox on your gift form. Running it: 30 to 60 minutes a month at 50 gifts. No lawyer is needed to start.

What it saves is harder to see. It doesn't prevent every miss. Creators forget. What it changes is your position when a miss happens: you can show written guidance, monitoring, and a documented fix, which are the exact three things 255.1(d) asks for. It also turns an awkward judgement call into a routine message.

## FAQ

### Do small brands need an influencer disclosure policy?

If you gift product to creators regularly, yes, and it only needs to be one page. The FTC's Endorsement Guides say advertisers should give endorsers disclosure guidance, monitor compliance, and take action on misses. A written policy is the cheapest way to show you do all three. The FTC says the scope of a program depends on the risk, so a small gifting brand without health claims doesn't need anything elaborate.

### What should an influencer disclosure policy include?

Five things: the exact disclosure wording creators must use, where creators agree to it (brief, gift form, or agreement), how often you check posts, a log of what you checked and found, and an escalation rule for misses. Add a do-not-say list if you sell supplements, skincare, or anything with health claims.

### How often should I check creators' posts for disclosure?

The FTC doesn't set a number. It says to periodically search for what creators are saying and to act on problems. A realistic cadence for a small brand is to check every first post from a new creator within a few days of it going live, then spot-check a sample of repeat creators each month. At 50 gifts a month that takes roughly 30 to 60 minutes.

### Do creators need to sign the disclosure policy?

They don't need to sign the internal policy itself. They need to receive the disclosure instruction in writing and ideally agree to it. A required checkbox on the gift form, a line in the brief, or a clause in a written agreement all work. What matters is that you can show each creator was told before they posted.

### Is #gifted an acceptable disclosure under the policy?

Not on its own. The FTC's endorsement FAQ says "Gifted" by itself, without a brand reference, is likely to be ambiguous. Specify "Gifted by @brand", "Thanks @brand for the free product", or "#ad" in the first line. For UK creators, specify "Ad", because the CMA treats #gifted as ambiguous.

## FAQ

**Do small brands need an influencer disclosure policy?**
If you gift product to creators regularly, yes, and it only needs to be one page. The FTC's Endorsement Guides say advertisers should give endorsers disclosure guidance, monitor compliance, and take action on misses. A written policy is the cheapest way to show you do all three. The FTC says the scope of a program depends on the risk, so a small gifting brand without health claims doesn't need anything elaborate.

**What should an influencer disclosure policy include?**
Five things: the exact disclosure wording creators must use, where creators agree to it (brief, gift form, or agreement), how often you check posts, a log of what you checked and found, and an escalation rule for misses. Add a do-not-say list if you sell supplements, skincare, or anything with health claims.

**How often should I check creators' posts for disclosure?**
The FTC doesn't set a number. It says to periodically search for what creators are saying and to act on problems. A realistic cadence for a small brand is to check every first post from a new creator within a few days of it going live, then spot-check a sample of repeat creators each month. At 50 gifts a month that takes roughly 30 to 60 minutes.

**Do creators need to sign the disclosure policy?**
They don't need to sign the internal policy itself. They need to receive the disclosure instruction in writing and ideally agree to it. A required checkbox on the gift form, a line in the brief, or a clause in a written agreement all work. What matters is that you can show each creator was told before they posted.

**Is #gifted an acceptable disclosure under the policy?**
Not on its own. The FTC's endorsement FAQ says 'Gifted' by itself, without a brand reference, is likely to be ambiguous. Specify 'Gifted by @brand', 'Thanks @brand for the free product', or '#ad' in the first line. For UK creators, specify 'Ad', because the CMA treats #gifted as ambiguous.