New Endorsement Guides Include Big Changes, But Few Surprises

In May 2022, the FTC proposed changes to its Endorsement Guides. Among other things, those changes created more prescriptive disclosure requirements for endorsements, imposed various requirements for consumer reviews, and clarified that all parties involved in a marketing campaign could be held liable for lapses. At that time, we analyzed the FTC’s proposed changes and examined how they might impact advertising practices and influencer marketing.