The disclosure requirements
Two bright lines apply when users earn product credits for public posts. The connection must be disclosed in the post, in words its reader understands, and the reward can never depend on what the post says.
Last reviewed: 19 September 2026. Revised after a legal review of how disclosure works across markets. Earlier versions of this page presented the branded hashtag as the answer everywhere; it is an answer for the United States, and other markets ask for more. An operator's summary, not legal advice. Penalties and platform policies change; check dated items against the source, and have counsel review your mechanics.
Compliance under advertising law isn’t a hurdle to hide, it’s the mechanism that makes the entire system believable.
Bright line #1: the connection must be disclosed
Credits for a post are compensation, a material connection under the FTC Endorsement Guides (16 CFR Part 255). Credits, higher limits and access all count; it does not have to be money. That requires a clear disclosure in the post. Two things are commonly mistaken for one:
- Tagging the product is not disclosure. An @mention names the product and says nothing about compensation.
- Vague insider tags are not disclosure. A bare "#ambassador" does not tell the reader the poster earns something.
The FTC's own FAQ calls a bare "#partner" ambiguous and a branded form like "#XYZ_Partner" understandable: the brand name fused to the relationship. It also says a hashtag is optional. Plain words that name the advertiser do the same job, and what the FTC asks is that a reader understands. The amount need not be disclosed. The connection must.
How to write a rewarded post on Earnesty
Choose an approved disclosure in the language you intend to use. Put the phrase upfront when your status page requires it; otherwise follow the placement shown. Include the brand’s exact @handle in your post. The phrase and handle can be in different sentences. Keep both through the five-day review.
Ad — Having fun using @Brand. Look what I built! @EarnestyRewards
This English example puts the phrase upfront and mentions the brand in the sentence. Use the approved language option shown for your post. The Earnesty mention does not replace the brand mention.
The rules change at the border
That is the United States. An earned tier's users post from wherever they are, and most other markets have their own rule about rewarded posts. Three things vary.
- The word. The UK's Competition and Markets Authority wants an explicit advertising label and advises against "#sponsored". Germany's media authorities expect Werbung. France's advertising regulator expects Publicité or Collaboration commerciale, and "partenariat" alone is not enough. Italy, Spain, Portugal, the Netherlands, Japan and South Korea each name their own.
- The language. The FTC says a disclosure should be in the language of the endorsement. A post written in Spanish needs a disclosure a Spanish reader understands, wherever the program is run from.
- The place. The FTC does not prescribe a position. Guidance in Germany, France, Italy, Portugal and South Korea expects the reader to meet the disclosure first, and the UK expects a post to be recognizable as advertising immediately.
These come from different kinds of source: legislation in some places, a regulator's guidance in others, an industry code in others. They also change.
What this asks of an earned tier
Less than it sounds like, if the tier is run on software built for it. Your users are shown the disclosure their post needs, in their language, before they write it. Each post is checked against the rule for the market you promote in, and checked again a few days later. From your side it is one decision: where you promote.
The part to avoid is the shortcut. A check that a post contains one English tag takes an afternoon to build and covers one market. The posts it approves from everywhere else have not met their own market's rule.
Bright line #2: never condition the reward on sentiment
The FTC's 2024 rule on incentivized reviews (16 CFR Part 465) prohibits rewards conditioned, expressly or by implication, on a particular sentiment. Three things make it the sharper line:
- Disclosure does not cure it. "Earn credits for a 5-star review, disclosed!" is still illegal.
- Implication counts. "Share why you love us" is sentiment-shaped without a star in sight.
- It cuts both ways. Paying only for criticism is conditioned on sentiment too.
The compliant shape rewards the act: post about the product, make a suggestion, post a tip. A program that visibly pays the same for a complaint as for praise is its own best evidence.
The rule is written for consumer reviews, and an ordinary rewarded post is usually a testimonial rather than a review. Hold the whole program to it anyway. One sentiment-neutral rule for every post leaves no argument about which kind of post a given one was.
Neutrality and disclosure do not cover authenticity. A disclosed post about an experience the poster never had is still a fabricated testimonial (16 CFR 465.2). Ask for what people actually did with the product, and never hand them words that claim an experience on their behalf.
The rule founders trip on first
The disclosure says the post was rewarded. It does not say the poster works for you. An employee, contractor, or investor who posts to earn needs a plain sentence as well, "I work at Acme", near the start. This bites hardest in launch week, when the first posts come from the team.
The platform layer
Platform policy sits on top of the law. X’s policy asks for its Paid Partnership label on compensated organic posts, and credits count as compensation. The label and the in-text line do different jobs, and the label cannot stand in for the line: it drops off in embeds and screenshots, and the FTC warns against assuming a platform’s tool is enough on its own. X also does not offer the label to every account, so the in-text line is the part every rewarded post can carry. Where the label is available, use both.
X also prohibits paying for engagement. Rewarding someone for their own post is one thing; paying for likes, reposts, replies or follows is another, and it is not allowed whatever the post discloses.
One hard exclusion: X prohibits paid-partnership content for financial products and gambling. Products in those categories cannot run this on X at all.
Review platforms are stricter still. G2 caps review incentives at $100 and counts credits, which is one reason a well-designed earned tier never rewards reviews.
Who answers for it
You do. The advertiser stays responsible for a program it hands to someone else, and the FTC says the companies that run such programs are not immune either. What regulators look for is guidance to the people posting, checks on what they post, and action when a post falls short. A reminder that is ignored while the reward still goes out is not action. There is no safe harbor, and a program that does all three is in a far better position than one that does none.
Questions operators ask
Must the disclosure phrase sit beside the brand mention?
Earnesty checks them independently: the approved phrase must meet the selected market’s placement rule, and the exact brand @handle must appear in the post. They can be in different sentences. The copyable example puts them together for convenience.
Do users have to disclose that they earn credits for posting?
Yes. Credits for a post are a material connection under the FTC Endorsement Guides, and most other markets treat the post as advertising. Both require a clear disclosure in the post itself. A tag that only names the product does not count. A branded relationship tag like #Acme_Partner does in the United States, and other markets expect their own advertising word.
Does the disclosure have to be a hashtag?
No. The FTC says a hashtag is optional; what matters is that a reader understands the post is rewarded. A branded hashtag such as #Acme_Partner is a form FTC staff guidance supports, and plain words that name the advertiser work too. Outside the United States, check what each market expects, because several name a specific word.
Is one disclosure enough for users in every country?
Usually not. The FTC accepts a brand-linked partner tag and does not prescribe where it sits. The UK expects an explicit advertising label. Germany, France, Italy, Portugal and South Korea name their own words and expect the reader to see them first. A program whose users post from more than one country has to meet each market, in the language of each post.
Is it legal to pay users for positive reviews if they disclose?
No. The FTC's 2024 rule on incentivized reviews prohibits rewards conditioned on a particular sentiment, and disclosure does not cure it. Rewarding participation is legal; rewarding a required opinion is not.
Does the platform's Paid Partnership label replace the written disclosure?
No. Platform labels drop off in embeds and screenshots, and the FTC warns against assuming a platform tool is enough on its own. X also does not offer its label to every account, so the written line is the part every rewarded post can carry.
Can users earn credits for G2 or app-store reviews?
Treat reviews as off-limits. Review platforms add their own limits on incentives, and G2 explicitly counts credits. An earned tier rewards public posts with a disclosure, not reviews.
Why compliance is a feature, not a tax
The disclosure is also the trust mechanism. An audience that can see the deal can weigh the post; an audience that discovers a hidden deal writes the product off. That is why the rules above belong in the verifier, checked before any credit is granted, not in a policy document nobody reads.