Yes, UGC videos need FTC-style disclosures whenever there’s a material connection (payment, free product, discount, affiliate commission, or any other perk) that could affect how viewers weigh the recommendation, and using “#ad” is one common, acceptable way to do it.
UGC confuses people because it often looks like a normal customer review. The FTC cares about whether a reasonable person would want to know the relationship before trusting the message. If the creator was compensated in any way, disclose it clearly and early. If you’re a Florida business (Orlando included), this also lines up with the basic consumer protection idea in Florida’s deceptive and unfair trade rules: don’t market in a way that misleads people about what’s “organic” vs paid.
Where this shows up most for local businesses is when you run UGC as paid social ads or post it on your brand profile. If it’s an ad you’re running from your business account, the viewer already knows they’re seeing brand advertising, but you still cannot imply the creator is an unpaid, independent customer if they were paid. If the creator posts it on their own account, a disclosure is almost always needed when there’s compensation.
| UGC situation | Do you need a disclosure? | What “good” looks like |
|---|---|---|
| Creator is paid (cash, gift card, free service, free product, discount) and posts on their own TikTok/IG/YouTube | Yes | Start caption with “Ad” or “Paid partnership with [Brand]” or use “#ad” near the beginning (not buried). In video, add on-screen text “Ad” and, when practical, a quick spoken disclosure. |
| Creator gets an affiliate link or commission | Yes | “I earn a commission if you buy” plus “Ad/Affiliate” placed where viewers will see it before the link matters (caption top, on-screen, and near the link area). |
| “Gifted” product with no required post, but creator chooses to post | Usually yes | Use plain language like “Gifted by [Brand]” or “Free product” early, not vague tags. |
| Employee, owner, family member, or close relationship talking up the business | Yes | “I work for [Brand]” or “My spouse owns [Brand]” placed up front. |
| You post UGC on your brand account as an ad or organic post and the creator was paid | Often | Avoid framing it as a random customer review. If it’s styled like a testimonial, add a simple note in the caption like “Paid creator” or “Creator partnership.” |
Placement matters as much as wording. For short-form video (Reels, TikTok, Shorts), the safest pattern is: disclosure on-screen in the first seconds, disclosure in the caption before people tap “more,” and no tiny text or low-contrast overlays. For Stories, put it on every frame that includes the endorsement, because people may skip around.
If you’re ordering UGC from creators and turning it into ads, we bake disclosure planning into the brief so you don’t end up reshooting or pulling ads later. That’s part of how we run UGC production for local brands that want performance without compliance headaches.
One more practical rule: if you’re debating whether it “counts,” disclose. Over-disclosing rarely hurts conversions, but under-disclosing can create trust issues fast, especially in healthcare, dental, legal, and home services where people are already cautious.
If you want the disclosures to look natural (not awkward) and still be hard to miss, we can also map them to each platform’s post format when we manage social media marketing. The same transparency that builds compliance also supports credibility, which ties directly to the trust signals we talk about in E-E-A-T for local businesses.
