Guides Concerning the Use of Endorsements and Testimonials in Advertising

What this rule actually says

The FTC wants to crack down on fake endorsements and misleading testimonials in advertising. If a customer says "this AI saved my life" in a marketing video, the company needs to prove that's a real, typical experience—not cherry-picked or paid-for hype. The rules also require disclosure when endorsers have financial relationships with the company, and they're tightening standards on what counts as "typical results."

Who it applies to

• If you use customer testimonials or case studies in marketing (blog posts, landing pages, demo videos, social media): this applies to you.
• If you pay customers, influencers, or beta testers to promote your product: this definitely applies to you.
• If you're in the US: the FTC has jurisdiction. Non-US founders selling to US customers should pay attention.
• Which AI use cases trigger it: medical scribes, hiring assistants, and support chatbots are all high-risk because people make serious decisions based on them. Claims like "99% accuracy" or "doctors prefer this" get extra scrutiny.
• What's in scope: text testimonials, video reviews, case studies, influencer posts, user quotes on your website, and real customer results you showcase.
• What's out of scope: internal data, anonymous aggregate metrics (e.g., "our users report 40% time savings"), and honest product descriptions without claimed endorsement.

What founders need to do

1. Audit your marketing right now (2-3 hours): screenshots, case studies, testimonials, and customer quotes. Flag anything that looks like it could be misconstrued as typical when it's actually an outlier.

1. Get explicit permission and proof (1 day, one-time): before using any customer name, face, or quote publicly, get written consent. Keep records of the actual customer and their real results.

1. Add clear disclosures (2-3 hours, one-time): if a customer was paid, got free access, or has a financial tie to the company, say so visibly—not buried in footnotes.

1. Avoid absolute claims you can't back up (ongoing): "eliminates hiring bias" is riskier than "helps reduce hiring bias." Document your basis for any performance claims.

1. Monitor your community (ongoing): if users make wild claims about your product in public forums or testimonials, correct the record gently. You're liable for endorsements you appear to endorse.

Bottom line

Monitor actively and document everything now—this rule targets misleading claims and undisclosed paid endorsements, which are common in early-stage AI marketing, so tighten up before enforcement kicks in.