#InfluencerInfractions: How Influencers Comply (or Don’t) with FTC Guidelines

Terry, Christopher, Troha, Emma, Micich, Anastasia & Lausten, Cecilia

Journal: Journal of Law, Technology, & the Internet

Volume: 17

First Page: A6

Year: 2026

Bluebook Citation: 17 J. L. TECH. & INTERNET A6 (2026)

Author: Christopher R. Terry: all 13 publications


Abstract

The Federal Trade Commission (FTC) released endorsement guidelines of sponsored content in 2023, including stipulations of clear and conspicuous disclosure, to combat content disguised as original, while actually having commercial intent. This paper examines compliance with these guidelines among travel influencers on Instagram. Overwhelmingly, influencers are not properly disclosing potential commercial sponsorship in their posts, and even good faith attempts to disclose are more often than not non-compliant with the FTC’s guidelines. Implications of these findings are discussed.

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