FTC Disclosures Still A Focus In Interactive Media

The Federal Trade Commission's (FTC) advertising disclosure rules for "material connections" are not new. The FTC has long required that advertising contain clear and conspicuous disclosures of endorsements and other material connections to ensure that consumers are not misled by hidden commercial relationships.¹ The longstanding expectation is simple: brands, influencers, and endorsers must make clear and conspicuous disclosures about the nature of their connection in a manner that is hard to miss.² What is new and perhaps not as simple, however, is the practical application of these principles in the rapidly changing world of interactive media.

Interactive media encompasses digital experiences where users actively participate in or engage with content (i.e., more than just static ads). This includes livestreams, video gaming environments, and short-form videos on platforms like TikTok, Instagram, and Twitch. In these spaces, advertising content can be woven into