Is UGC content legal in ads?

Under the FTC's endorsement guidance, a creator who has not used a product cannot describe results as their own, and paid endorsements need a clear disclosure. Source: FTC: Endorsements, Influencers, and Reviews, checked on 29 October 2026.

The FTC's health products guidance says health claims need competent and reliable scientific evidence, and that a testimonial showing results that are not typical is likely deceptive even with a "results not typical" line. Source: FTC Health Products Compliance Guidance, checked on 29 October 2026.

A creator release for a health brand should cover paid usage, whitelisting, the length of use and what the creator may not say. Our free UGC creator agreement template and FTC disclosure generator help with both.

For legal questions about your own ads, ask your counsel.

The FTC says employees of an ad agency or public relations firm have a connection to the advertiser, which should be disclosed in all social media posts. Source: FTC's Endorsement Guides: What People Are Asking, checked on 3 November 2026.

A platform's built-in disclosure tool does not by itself make the disclosure effective, and a disclosure in the lower corner of a video could be too easy to overlook. Source: FTC's Endorsement Guides: What People Are Asking, checked on 3 November 2026.

If a claim that needs a disclosure is made both visually and audibly, the FTC says the disclosure should be made both visually and audibly too. Our UGC agency page shows how creator videos are scripted for this. Source: FTC Health Products Compliance Guidance, checked on 3 November 2026.

The FTC says anyone participating in deceptive marketing is potentially liable under FTC law. That reaches past the brand to the people who make and run the ad. Source: FTC Health Products Compliance Guidance, checked on 3 November 2026.

A company that pays and directs influencers needs reasonable programs to train and monitor them, and an agency would be responsible for employees who did not follow its instructions or who made unsubstantiated performance claims. Source: FTC's Endorsement Guides: What People Are Asking, checked on 3 November 2026.

The endorsement guidance does not provide a safe harbor from liability, and the health products guidance does not have the force or effect of law. Both describe how the FTC reads ads. See our UGC ads page for the format itself. Source: FTC's Endorsement Guides: What People Are Asking, FTC Health Products Compliance Guidance, checked on 3 November 2026.

Usage terms decide how long you can run the ad, so match them to your testing plan. Whitelisting lets you run ads from the creator's account; set an end date for it.

Never ask a creator to describe results they did not have.