Meeting FTC Disclosure Requirements

In December 2009, the Federal Trade Commission (FTC) released a series of guides for the use of endorsements and testimonials in advertising. As a Govology Affiliate, you are required to comply with the FTC guidelines at all times when promoting Govology services.

To make it easier, we came up with some examples of “good” and “bad” disclosures (see below). Please note that these examples are meant to provide guidance only and should not be construed as Govology’s legal advice to you.

To comply with the FTC requirements, you must disclose to consumers that you are receiving commissions or payment for promoting Govology services. Failure to do so may result in immediate removal from our affiliate program and cancellation of any pending commissions or payments.

All disclosures must meet four basic requirements. They must be frequent, clear, conspicuous, and require no scrolling or other type of user action to locate.

Below we explain what these requirements mean in relation to Govology.

  1. Frequent: Your disclosure must appear on any website, social media post, video, article, or review that promotes Govology using affiliate links or paid placements.

  2. Clear: It must be immediately clear that you may receive compensation from Govology for your review, promotion, or recommendation.

    • Examples of CLEAR disclosures you can use when promoting Govology:

      • In-text form:
        • Disclosure: We are a professional review site that receives compensation from the companies whose products we review. We test each product thoroughly and give high ratings to only the very best. We are independently owned and the opinions expressed here are our own.

      • In social media:
        • Use hashtags commonly known to consumers such as #ad or #sponsored in any social media post that includes affiliate links.

      • In video format:
        • You have to verbally state before you talk about our product that “Govology has sponsored this video” or “I’m a Govology Affiliate so I may receive compensation if you purchase a Govology course after watching this video.” Having an annotation or note in the description box is a plus.
        • For Youtube: Check the “video contains paid promotion” box under the “Content declaration” section when you upload the video.

    • Examples of UNCLEAR disclosure:

      • In-text form:
        • Disclosure: We are a website that needs compensation to operate like any other website on the internet. We may receive consideration for our reviews but we are totally unbiased and do not accept paid reviews or fake reviews claiming to be something they are not.
        • Clarification: this “disclosure” is omitting the most important information: that a commission is paid for purchases made through links in the post, or that commission or conversion rates are influencing the placement or content of the rankings or reviews.

      • In social media:
        • Do not use the hashtags #aff or #affiliate in any social media post that includes affiliate links.
        • Clarification: the social media hashtags #aff or #affiliate are not proper disclosures as these terms are not familiar to the average consumer.

      • In video format:
        • Just stating that you got a “sneak peek” is not sufficient as it doesn’t clearly state to consumers your relationship with Govology.
        • Just having a link to an official disclosure in the description box or as an annotation is not sufficient.
        • Disclosures can’t be placed somewhere that could be easily missed, for example at the end of your video, which is why you should always state it in your video before you talk about Govology.

  3. Conspicuous:  The disclosure must be clear and easy to see. It should begin with the word “disclosure.” No scrolling should be necessary in order to find the disclosure. For the disclosure to be considered clear, make sure you comply with the following guidelines:
    • Font should be: 
      • At least as large as the main text on the page.
      • In a color other than black or gray.
      • In contrast with both its background and the main text.
      • Darker than its background or the main text.
    • Video disclosure should be:
      • Mentioned in the video itself and be long enough to be noticed, read, and understood by consumers.

  4. Require No Action: Your disclosure must be immediately evident to a typical visitor to your site who views a review, ranking, or endorsement on a PC, Mac, or mobile device. A visitor should not need to scroll, click, or hover to learn that you receive compensation. If you do include a clickable link or additional information when a visitor hovers over text, the language of the link itself should reveal the fact that you receive compensation.

    • Example of a link that requires no action:
      • Disclosure: We are compensated for our reviews. Click here for details.
      • Keep this in mind: Simply telling the visitor that they can “Click/hover here to read our FTC disclosure” is not adequate. You need to signal through plain words, such as “Advertising Disclosure” that the “disclosure” is relevant to the potential for editorial bias due to commissions.

More information about the FTC Disclosure requirements is available at: