FTC Disclosure in YouTube Shorts: What Actually Satisfies the Rule
The FTC requires affiliate disclosures to be clear and conspicuous — before the recommendation. In a 60-second Short where the description is hidden during playback, most creators are non-compliant without knowing it.
The Core Problem: Descriptions Are Hidden During Shorts Playback
When a viewer watches a YouTube Short, the description is collapsed — they see the video, not the caption. A disclosure in the description is effectively invisible during the content experience. The FTC's "clear and conspicuous" standard requires the disclosure to be unavoidable at the point of recommendation — not in a place viewers have to tap to find.
What does NOT satisfy FTC disclosure for Shorts
Disclosure only in the description
Descriptions are hidden during Shorts playback. Viewers have to tap to see them. The FTC's 'clear and conspicuous' standard is not met by content the viewer has to seek out.
'#ad' or '#sponsored' hashtag in description only
Hashtags buried in collapsed descriptions have the same problem as full disclosure text — invisible during viewing.
Verbal disclosure at the end of the Short
FTC requires disclosure before the recommendation. A 58-second Short with disclosure at second 55 has already made the recommendation. Non-compliant.
YouTube's 'paid promotion' toggle alone
Adds 'Includes paid promotion' to the video — satisfies YouTube's platform policy but doesn't disclose the specific affiliate commission relationship the FTC requires.
Disclosure in a pinned comment
Comments appear below the video and require viewer action to access. Not clear and conspicuous at the point of recommendation.
What DOES satisfy FTC disclosure for Shorts
Verbal disclosure in the first 3–5 seconds
"This video contains affiliate links — I earn a commission if you buy through my link." Said before the first product mention. Compliant.
On-screen text overlay at the start of the Short
A clearly readable text overlay saying "AD" / "Affiliate" / "Paid partnership" displayed prominently in the first seconds of the video.
Both verbal AND description disclosure
Belt-and-suspenders: spoken disclosure in the video + written disclosure at the top of the description (visible when expanded). The combination is clearly compliant.
YouTube paid promotion toggle + verbal disclosure
Use YouTube's toggle (platform compliance) plus a spoken or on-screen disclosure of the commission relationship (FTC compliance). Both required.
Disclosure language that works for Shorts
Amazon affiliate Short — verbal opening
"Quick disclaimer — this is an affiliate link. As an Amazon Associate I earn from qualifying purchases."
Spoken in the first 5 seconds. Covers both FTC and Amazon's specific disclosure language.
TikTok Shop cross-posted Short — verbal
"This video contains affiliate links — I may earn a commission if you purchase through them."
Platform-neutral language. Works for Shorts posted to YouTube and TikTok simultaneously.
On-screen text overlay
"AD | Affiliate Commission Earned"
Large enough to read, displayed for at least 3 seconds at the start of the video.
Description top line (supplementary)
"⚠️ Affiliate links below — I earn a commission on purchases. As an Amazon Associate I earn from qualifying purchases."
Place before any links in the description. Still needs verbal or on-screen disclosure in the video itself.
YouTube's paid promotion toggle vs FTC requirements
YouTube offers a "paid promotion" disclosure toggle that adds "Includes paid promotion" to the video. This satisfies YouTube's platform policy but does not satisfy FTC requirements on its own.
The FTC requires disclosure of the specific material relationship — that you earn a commission from purchases, not just that the video is "sponsored." The toggle tells viewers something commercial is happening; it doesn't tell them you get paid when they buy.
Use both: YouTube's paid promotion toggle AND a verbal/on-screen disclosure of the affiliate commission relationship.
Check your Short script for disclosure compliance
BanProof flags missing, misplaced, or insufficient disclosures in Short scripts before you record.
BanProof.io is an independent AI compliance tool. FTC guidance based on the 2023 updated Endorsement Guides — verify current requirements at ftc.gov.