Case #250-2026: Administrative Closure – Mary Kay, Inc.

BBB NATIONAL PROGRAMS

Direct Selling Self-Regulatory Council
Case #250-2026: Administrative Closure – Mary Kay, Inc.

 



Company Description

Mary Kay Inc. (“Mary Kay” or “the Company”) is a global cosmetics and skincare company founded in 1963 and headquartered in Addison, Texas. The Company develops and distributes a broad range of beauty and personal care products and operates through a direct selling business model, marketing its products in numerous international markets through a network of independent beauty consultants.



Basis of Inquiry

The Direct Selling Self-Regulatory Council (“DSSRC”), a national advertising self-regulation program administered by BBB National Programs, initiated this inquiry as part of its ongoing, independent monitoring of advertising and marketing claims within the direct selling industry.

This matter pertained to 11 earnings claims disseminated on Facebook and Instagram. DSSRC expressed its concern that the claims conveyed messages suggesting that a typical Mary Kay salesforce member could achieve significant income, including representations of “financial freedom” and the ability to earn full-time income. DSSRC was concerned that such claims may communicate unsupported expectations regarding the income that would be generally expected through participation in the Mary Kay business opportunity.

The representative earnings claims set forth below formed the basis of this inquiry:

  1. “**Seeking Financial Freedom and Flexibility? Let’s Connect!** Are you ready to embrace a career that gives you flexibility, financial independence, and the power to be your own boss?” (December 2024)
  2. “I had to share this! OH WOW! Title: 😲$14,000,000.00 from her Mary Kay career.” (August 2025)
  3. “Extra income stream → flexible & fun, whether you want gift money or a career-level paycheck.”  (October 2025)
  4. “Title: ✨Unlock Beauty, Confidence & Financial Freedom with Mary Kay! Title: ✨” and “💡 Flexible & Rewarding : Work on your own terms—whether part-time or full-time—while earning unlimited income, bonuses, and even dream rewards like cars and trips!... #FinancialFreedom” (May 2025)
  5. “I am so glad I said “YES”

    ***15 of the Many Reasons Why Women Choose Mary Kay**
    Title: ✅Money-highest paying direct commission company in the U.S. @ 50% on all products.
    You can make Full Time pay for Part Time Work. Title: 💰
    a.)Recruiting Commissions of 4%, 9%, 13% paid from Corporate.
    b.) Move Up to 23% Plus Several Bonuses as a Director.
    Title: ✅Car Program-(new Title: 🚗every 2 years) & 85% of the insurance is paid for you, the tax & title are paid 100%, & you can choose to receive Title: 💵compensation if you don’t want the car. Title: 🚗
    Title: ✅Recognition & Prizes- We encourage you for every accomplishment no matter how small. Title: 🎉We encourage each other. We award Title: 🎁& prizes (jewelry, Title: 💎, & trips to places all over the Title: 🌎!)
    Title: ✅Freedom-from Corporate America, NO Glass ceilings, unlimited earning potential. You're your own BOSS! Title: 💪🏽” (December 2024)

  6. “$11,000,000 WOW!!!!

    Some claim you can’t make money in this business…Title: 💁🏻‍♀️
    So very honored to witness ‘belief barrier breakers’ be recognized on stage this morning, collectively earning over $30,000,000 in their Mary Kay ventures!!!” (July 2024)

  7. “I discovered how this business is not just about beauty, but about leveling up ourselves from career growth, luxury trips, high income, pink cars 🚗💗, to endless opportunities that bring both purpose and financial stability. #FinancialFreedom” (September 2025)
  8. “🌞 Looking for a Summer Job That Fits YOUR Schedule? 💄

    Let me help you start something beautiful with Mary Kay! Whether you’re saving for school, vacation, or just want extra spending money — this could be the perfect time to start your own business!...✅ Earn extra income (and rewards too!)…#FlexibleIncome” Image with copy stating “$300 x 12 weeks = $3600 in your pocket” (June 2025)

  9. “Are you seeking financial freedom…? Income Potential - Your earnings depend on your efforts, and many consultants achieve significant financial growth, with bonuses available for added incentive. The Mary Kay opportunity is a rewarding way to achieve financial independence”
  10. “I just paid one of my credit cards with my Mary Kay income!! 🥹💗

    If you’ve ever thought about joining me or wondered if Mary Kay could help YOU:
    👉 Extra income
    👉 Build savings
    👉 Fund your goals”
    (December 2025)

  11. “Mary Kay became more than just skincare for me. It became a way to contribute financially, pay bills, relieve stress, and feel proud of myself again. What started as a side thing turned into confidence, consistency, and real income — all while working around my life and my family. Whether you need a few hundred extra dollars a month or you’re dreaming bigger, this opportunity can work if you’re willing to show up.” (December 2025),


 

Company Position

Mary Kay appreciated DSSRC’s review of this matter and stated that it took seriously its obligation to ensure that its independent salesforce members marketed the Company’s business opportunity in a truthful and responsible manner. Upon receipt of DSSRC’s inquiry, Mary Kay initiated an internal review of the identified social media posts and worked directly with the field to secure their removal. The Company advised DSSRC that several of the posts had already been in the process of being addressed prior to receipt of the inquiry as part of its ongoing compliance monitoring efforts.

As a result of these efforts, seven of the 11 identified posts were removed shortly after DSSRC’s notice. Mary Kay explained that several of the remaining posts involved international salesforce members, which required additional coordination, and two U.S.-based salesforce members for whom escalated compliance measures were being pursued in accordance with Company policy. The Company represented that it anticipated resolving the remaining posts within the timeframe provided by DSSRC.

Mary Kay subsequently confirmed that three additional posts had been deleted, including the post disseminated by the Canada-based salesforce member. With respect to the one remaining active post, the Company informed DSSRC that the content had been disseminated by a salesforce member who was no longer affiliated with the Company. Mary Kay advised that, because it no longer had a direct relationship with the individual, it reported the post to Facebook and formally requested that the platform remove the content.

The Company maintained that it was committed to promoting accurate and substantiated representations of the Mary Kay business opportunity and stated that it would continue to take appropriate corrective action when it became aware of earnings claims that did not comply with applicable standards and Company policy.



Administratively Closed Resolution

Through its compliance and outreach efforts, Mary Kay facilitated the removal or modification of 10 of the 11 social media posts at issue in this inquiry. DSSRC acknowledged the Company’s good-faith actions to address the post that remained publicly available and determined that Mary Kay’s response under the circumstances was appropriate and consistent with self-regulatory expectations.

In its review, DSSRC concluded that the earnings claims at issue could reasonably convey the message that a typical Mary Kay salesforce member would be likely to earn substantial income—such as achieving “financial freedom” or “unlimited income”—through participation in the Company’s business opportunity. DSSRC determined that such representations may be reasonably interpreted as communicating expectations about generally achievable results that require appropriate substantiation and context.

The Federal Trade Commission’s (FTC) Business Guidance Concerning Multi-Level Marketing provides that earnings claims must reflect what participants can generally expect to earn. The FTC has cautioned that representations highlighting the potential for significant income are often not indicative of the results achieved by typical participants and, if not properly qualified, may mislead consumers.1 The FTC Guidance further explains that atypical income or lifestyle claims must be supported by competent and reliable evidence demonstrating that the represented results are typical. In the absence of such substantiation—and without clear and conspicuous disclosures regarding generally expected earnings—aspirational or high-level income claims may create a misleading impression of the opportunity.2

Consistent with this framework, DSSRC’s Guidance on Earnings Claims for the Direct Selling Industry advises companies and their salesforce members to refrain from using statements or imagery that suggest income levels beyond what an average participant could reasonably expect to achieve. DSSRC has identified the term “financial freedom” as particularly susceptible to consumer misinterpretation.3 Prior DSSRC decisions have found that aspirational language, when presented without adequate explanation or qualification, may reasonably be interpreted as a promise of substantial or life-changing income.4

With respect to the one post that Mary Kay was unable to have removed, the Company informed DSSRC that the content had been disseminated by an individual who was no longer affiliated with Mary Kay. The Company nevertheless undertook multiple attempts to contact the former salesforce member and request removal of the post. When those efforts were unsuccessful, Mary Kay reported the content to Facebook and requested that the platform disable it.

In light of the Company’s documented actions demonstrating genuine and good-faith efforts to address DSSRC’s concerns, DSSRC determined that administrative closure of the inquiry was appropriate.



Conclusion

DSSRC appreciated Mary Kay’s prompt and good-faith cooperation in addressing the earnings claims identified in this inquiry. Based on the Company’s actions to have 10 of the 11 posts identified in this inquiry removed, its escalation efforts with respect to the one remaining post, and its continued commitment to ensuring that earnings representations accurately reflect generally expected results, DSSRC determined that the matter was appropriately resolved through administrative closure.



Company Statement 

“Mary Kay takes consumer protection very seriously, dedicating significant time and resources to proactively monitor, review, and address the concerns raised by the DSSRC. When independent sales force members were found to have violated Company policies through the identified posts, they were contacted, provided with appropriate education, and, where necessary, subject to corrective action and/or termination from the Company.”



(Case #250, closed on 2/12/26)
© 2026 BBB National Programs







[1] See Fed. Trade Comm’n, Business Guidance Concerning Multi-Level Marketing, Section 13 (April 2024) https://www.ftc.gov/business-guidance/resources/business-guidance-concerning-multi-level-marketing#deceptive.

[2] Id.

[3] Direct Selling Self-Regulatory Council, Guidance on Earnings Claims for the Direct Selling Industry, Section 6(A)(2022).

[4] See DSSRC Case #51-2023: LifeWave, Inc. (June 2023).