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The disclosure has to ride in the email you paid for

Answer Put the paid connection in the email, beside the recommendation and the link. Federal Trade Commission staff say a reader needs to see the disclosure and the endorsement together. A line that appears only after the click is a different page, and readers may never connect it to the pitch that got them there.

A brass balance scale on a small wooden table in a worn blue room, with a chair and an open door letting in warm light
The two pans only mean something if the reader can see both of them.

The note that started this: FTC's Endorsement Guides: What People Are Asking, Federal Trade Commission staff, Endorsement Guides revised 2023.

The note that started this is the FTC staff page, FTC's Endorsement Guides: What People Are Asking. The Guides were revised in 2023. They are not a statute. Staff say the page is not a safe harbor, and that a particular ad is judged on its facts. They also say practices that depart from the Guides can become a Section 5 case. Section 5 is the part of the FTC Act that bars deceptive advertising. You do not need a courtroom to use the page as a buying question.

An endorsement, in their definition, is an advertising message that people are likely to believe reflects someone other than the sponsoring advertiser. A solo ad is that message. A stranger's list is recommending your offer, or you are renting an hour of someone else's voice. If there is a connection a significant minority of readers would not expect, and that connection would change how they weigh the recommendation, the Guides say it should be disclosed clearly and conspicuously. Payment is that connection. A commission on the click is that connection. A free product with the expectation of a mention is that connection.

Where does the affiliate disclosure have to sit in a solo ad?

In the email, next to the recommendation and the link. A disclosure that waits on the page after the click is separated from the sentence that did the selling.

Staff put it on a website first, and the transfer to a letter is direct. If you earn a commission when a reader buys through your link, disclose the relationship on the page so the reader can decide how much weight to give the endorsement. Their example sentence is plain: I get commissions for purchases made through links in this post. One disclosure can be enough when the review and the link are on screen together. If the review that contains the disclosure and the link are separated, readers may not make the connection. The closer the disclosure sits to the recommendation, the better.

They then say the same guidance applies any time you endorse a product and get paid through affiliate links, including a review on someone else's site and a tweet. The solo is that case. The recommendation is the email. The link is in the email. The disclosure belongs in the email. A footer on the landing page is the separated case they already described. Some readers will click and some will not. The ones who only read the letter never saw the line.

Staff also draw a narrower case you should not hide behind. If a page is obviously a paid advertisement, and selling the ad space does not change what you review or how prominent the review is, they say there may be nothing further to disclose, because the only connection is the sale of space. A solo from a list the reader joined for that sender's own mail is not that case. The reader thinks they are hearing from the person they know. The commission is the unexpected connection. Say it in the letter.

The words have a job. Staff say Paid link, sitting right next to the affiliate link, should be an adequate disclosure of the nature of the link. They say Commissionable link is probably not a clear disclosure. Write the sentence a person can understand without a glossary. Then put it where the link is.

This is the check on a solo ads for affiliate marketing buy. Read the swipe before you pay. If the disclosure is missing, or if it is a wink the reader has to translate, send it back. The buy solo ads page is the order. This note is the sentence that has to travel with the order.

Which words count as a clear affiliate disclosure?

Staff say a plain line such as I get commissions for purchases made through links in this post is the shape to use. Paid link right next to the link can be enough. Commissionable link is probably not clear.

Clearly and conspicuously is the 2023 phrase they tell you to go read in the Guides themselves. On this page they unpack it with three practical tests. Placement: the line has to catch the reader where they are already looking. Clarity: ordinary words, and if more than one product is mentioned, say which one is paid. Responsibility: the brand and the person endorsing own the disclosure. A platform tool does not carry it for them. Staff say it is safer to add your own line even when a platform offers a toggle.

A solo has no platform toggle. It has a from-name, a sentence, and a link. The line has to be in that sentence's neighborhood. A hashtag the reader has never been taught, or a word like commissionable that sounds like a setting, fails the clarity test they wrote down. Use the example they were willing to put in print.

They also refuse the idea that everyone already knows. Some creators are paid and some are not. A financial arrangement that is obvious to part of the audience is still a problem if it would mislead a significant minority. The list you are renting is not a room where every subscriber has taken a marketing course. Assume the connection needs the sentence.

If you are the one selling the send, the page has a program for you too. Advertisers who use a network are told to explain what members may say, to instruct them on exactly how to disclose the connection, to look at what those members actually publish, and to act when the practice is questionable. A seller who will not show you the swipe with the disclosure already in it has skipped the second step. You are allowed to wait.

Does a pre-written swipe still have to be the sender's real opinion?

Yes. There is nothing inherently wrong with a pre-written post if the person sending it is being truthful. If the picture or the sentence claims a use or a result they did not have, the message is misleading.

Staff say a brand may hand several people the same image or the same text. The question is whether the message claims a use or an experience that did not happen. Endorsements have to reflect the truthful experiences and opinions of the people sending them. A solo swipe that says I use this every morning, sent by someone who has not used it, is the case they flagged. A swipe that says the letter is a paid placement, and then describes the offer without inventing a personal result, can be honest. Ask which one you were given.

The same page handles the income screenshot and the before-and-after. Endorsements of specific results are read as what others can expect. The phrases Results not typical and Individual results may vary do not change that reading. The advertiser either has proof the result is typical, or clearly discloses the result people can generally expect in the situation the ad shows. A solo that leads with one person's outlier number, and then shrugs, is still making the claim. Ask for the ordinary result in the same sentence, or take the number out.

When you pay, you are choosing the message that will sit in someone else's from-name. Read it as if you had to say it. Keep the disclosure next to the link. Keep the result inside what you can actually show. The people who want a rented hour so they can skip that reading will call the line compliance clutter. The line is the part a significant minority of the list is entitled to see before they click. Put it in the email. Then pay for the hour.