Lessons from NAD on Influencer Marketing and Consumer Trust
Annie M. Ugurlayan, Assistant Director, National Advertising Division, BBB National Programs
Content creators or “influencers” are not a new phenomenon (think Coco Chanel), but they are increasingly ever-present. Whether promoting pet products or cosmetics or urging you to be more civic-minded, influencers comprise a growing community upon which brands big and small rely to connect with consumers. While such engagement, on its face, is not problematic, it can be if consumers cannot readily distinguish an influencer’s organic post from advertising on behalf of a brand.
In 2025, BBB National Programs’ National Advertising Division (NAD) published the Influencer Trust Index, a survey of U.S. consumers that explores various topics related to influencer marketing. This research highlighted the important role transparency and disclosures play in building and maintaining consumer trust.
The Index’s findings helped inform the development of the Institute for Responsible Influence (IRI), a recently launched initiative of BBB National Programs’ Center for Industry Self-Regulation (CISR). IRI’s training and certification program was designed to meet the needs of both brands and content creators by helping creators better understand disclosure requirements relating to brand relationships in accordance with the Federal Trade Commission’s (FTC’s) Endorsements and Testimonials Guides, align content with established advertising standards, and gain practical guidance for managing brand collaborations.
First, while consumers (especially the younger demographic) generally recognize that influencers often promote products, an influencer’s failure to disclose their relationship with a brand is the biggest reason for distrust. Further, most survey participants said they were unsure whether hashtags such as #ad or #sponsored made the influencer endorsement more, or less, trustworthy (only 14.8% said more).
Second, the vast majority of survey participants (especially the younger demographic) agreed that the need for honest reviews, even if negative, is paramount. Transparency is an essential component of brand loyalty.
Third, the survey indicated that an influencer certification could bolster consumer trust – results were roughly the same for those who agreed and were unsure, but 37% of respondents said they would be more likely to purchase a product based on an influencer’s recommendations if they were certified.
IRI offers a creator training and certification program designed to support compliance with advertising standards and strengthen consumer trust in influencer marketing – all while helping creators develop and strengthen brand relationships. Crucially, the initiative is backed by TikTok, whose platform hosts thousands of creators promoting products and the brands with which they partner. IRI’s support by brands, agencies, and platforms will enhance transparency and bolster trust in advertising.
1. When in doubt, disclose material connections.
Brands and content creators have varied relationships. Some content creators are brand ambassadors and the content creators’ collaboration is with the ad agency or creator agency (see NAD Case #7364: 1Up Sports Marketing), while others involve a gifting relationship where the brand works directly with the content creator (e.g., the gifting of products in exchange for social media content) (see NAD Case #7368: Revolve Group). Still others involve no current formal relationship but one where free products have been given to the content creator in the past (see NAD Case #7453: Huda Beauty).
Consumers may not be privy to the nature of the relationship brands have with content creators. Regardless of how formal or informal, where there is an unexpected relationship between the content creator and the brand, that connection must be “clearly and conspicuously” disclosed in the endorsement (see NAD Case #7489: Agendia, Inc.).
“Clear” means unambiguous and does not mean simply tagging the brand. Content creators often tag brands with which they wish to, but do not, have a relationship, so a tag alone does not communicate that a material connection exists. Even when a creator does clearly disclose a relationship with a brand, that disclosure may not be enough if it is easy to miss. The disclosure must also be conspicuous – don’t hide the ball. Consumers should not have to click on the “learn more” tab to see the disclosure (see NAD Case #7224: Fenty Skin, LLC). Likewise, disclosures relating to endorsements in videos need to appear in the videos themselves.
2. Make it easy for the content creator to know the rules of the road.
IRI aside, simply directing content creators to read the FTC Endorsement Guides or the FTC’s “What People are Asking” companion FAQs and instructing them to comply with those materials may not be sufficient to ensure full compliance. Brands and agencies should also provide training for content creators that includes a list of acceptable and unacceptable claims and other dos and don’ts so they can make compliant ads. Brands should ensure influencer agreements require compliance with the FTC guidelines (for example, making it clear they need to have actually used the product and voice their honest opinions).
3. Be vigilant about compliance.
Rinse and repeat is the name of the game – brands must monitor content creators’ posts to ensure compliance and consider providing refresher training for them. While many compliance issues can be addressed through education and guidance, repeated noncompliance may require additional action.
When a brand is on notice about repeated noncompliant posts by a content creator, it is the brand’s responsibility to address the issue and, where appropriate, sever the relationship with the content creator. Brand integrity and trust can easily be lost and are difficult to rebuild, so make sure you choose creators committed to transparent and responsible advertising practices such as those who are IRI-certified.
Content creators or “influencers” are not a new phenomenon (think Coco Chanel), but they are increasingly ever-present. Whether promoting pet products or cosmetics or urging you to be more civic-minded, influencers comprise a growing community upon which brands big and small rely to connect with consumers. While such engagement, on its face, is not problematic, it can be if consumers cannot readily distinguish an influencer’s organic post from advertising on behalf of a brand.
In 2025, BBB National Programs’ National Advertising Division (NAD) published the Influencer Trust Index, a survey of U.S. consumers that explores various topics related to influencer marketing. This research highlighted the important role transparency and disclosures play in building and maintaining consumer trust.
The Index’s findings helped inform the development of the Institute for Responsible Influence (IRI), a recently launched initiative of BBB National Programs’ Center for Industry Self-Regulation (CISR). IRI’s training and certification program was designed to meet the needs of both brands and content creators by helping creators better understand disclosure requirements relating to brand relationships in accordance with the Federal Trade Commission’s (FTC’s) Endorsements and Testimonials Guides, align content with established advertising standards, and gain practical guidance for managing brand collaborations.
The Influencer Trust Index Report
The Influencer Trust Index was conducted in February 2025 with 3,720 U.S. consumers ages 18- 65. It was designed to determine (1) if there is a demand for more transparency in influencer marketing, and (2) whether a formal certification for influencers backed by industry self-regulation would increase consumer trust while helping to ensure truth in advertising. The results may surprise you.First, while consumers (especially the younger demographic) generally recognize that influencers often promote products, an influencer’s failure to disclose their relationship with a brand is the biggest reason for distrust. Further, most survey participants said they were unsure whether hashtags such as #ad or #sponsored made the influencer endorsement more, or less, trustworthy (only 14.8% said more).
Second, the vast majority of survey participants (especially the younger demographic) agreed that the need for honest reviews, even if negative, is paramount. Transparency is an essential component of brand loyalty.
Third, the survey indicated that an influencer certification could bolster consumer trust – results were roughly the same for those who agreed and were unsure, but 37% of respondents said they would be more likely to purchase a product based on an influencer’s recommendations if they were certified.
Creation of the Institute for Responsible Influence
Enter the IRI. Launched in April 2026 with the support of leading advertising industry organizations, brands, creator platforms, and advertising agencies, IRI provides creators with practical training as well as ongoing monitoring and educational outreach to reinforce responsible practices.IRI offers a creator training and certification program designed to support compliance with advertising standards and strengthen consumer trust in influencer marketing – all while helping creators develop and strengthen brand relationships. Crucially, the initiative is backed by TikTok, whose platform hosts thousands of creators promoting products and the brands with which they partner. IRI’s support by brands, agencies, and platforms will enhance transparency and bolster trust in advertising.
NAD Influencer Guidance
NAD has long provided guidance in the realm of influencer marketing, largely through its monitoring program. Drawing on those case decisions, here are some key takeaways for brands, agencies, and creators:1. When in doubt, disclose material connections.
Brands and content creators have varied relationships. Some content creators are brand ambassadors and the content creators’ collaboration is with the ad agency or creator agency (see NAD Case #7364: 1Up Sports Marketing), while others involve a gifting relationship where the brand works directly with the content creator (e.g., the gifting of products in exchange for social media content) (see NAD Case #7368: Revolve Group). Still others involve no current formal relationship but one where free products have been given to the content creator in the past (see NAD Case #7453: Huda Beauty).
Consumers may not be privy to the nature of the relationship brands have with content creators. Regardless of how formal or informal, where there is an unexpected relationship between the content creator and the brand, that connection must be “clearly and conspicuously” disclosed in the endorsement (see NAD Case #7489: Agendia, Inc.).
“Clear” means unambiguous and does not mean simply tagging the brand. Content creators often tag brands with which they wish to, but do not, have a relationship, so a tag alone does not communicate that a material connection exists. Even when a creator does clearly disclose a relationship with a brand, that disclosure may not be enough if it is easy to miss. The disclosure must also be conspicuous – don’t hide the ball. Consumers should not have to click on the “learn more” tab to see the disclosure (see NAD Case #7224: Fenty Skin, LLC). Likewise, disclosures relating to endorsements in videos need to appear in the videos themselves.
2. Make it easy for the content creator to know the rules of the road.
IRI aside, simply directing content creators to read the FTC Endorsement Guides or the FTC’s “What People are Asking” companion FAQs and instructing them to comply with those materials may not be sufficient to ensure full compliance. Brands and agencies should also provide training for content creators that includes a list of acceptable and unacceptable claims and other dos and don’ts so they can make compliant ads. Brands should ensure influencer agreements require compliance with the FTC guidelines (for example, making it clear they need to have actually used the product and voice their honest opinions).
3. Be vigilant about compliance.
Rinse and repeat is the name of the game – brands must monitor content creators’ posts to ensure compliance and consider providing refresher training for them. While many compliance issues can be addressed through education and guidance, repeated noncompliance may require additional action.
When a brand is on notice about repeated noncompliant posts by a content creator, it is the brand’s responsibility to address the issue and, where appropriate, sever the relationship with the content creator. Brand integrity and trust can easily be lost and are difficult to rebuild, so make sure you choose creators committed to transparent and responsible advertising practices such as those who are IRI-certified.