Where does an affiliate disclosure actually have to go in a video?
Almost every faceless channel handles affiliate disclosure the same way: a line in the description, usually under a wall of links, often below the fold. According to the FTC’s own guidance, that is close to a worked example of how not to do it.
This one is worth getting right. It isn’t a platform policy you can absorb a strike over — it’s consumer protection law.
When you have to disclose
You disclose when you have a “material connection” to the brand. The FTC defines that as “a personal, family, or employment relationship or a financial relationship – such as the brand paying you or giving you free or discounted products or services.”
An affiliate commission is a financial relationship. So yes.
A few edges people miss:
- Free or discounted product counts, even if nobody asked you to mention it. “If a brand gives you free or discounted products or other perks and then you mention one of its products, make a disclosure even if you weren’t asked to mention that product.”
- Being unbiased doesn’t exempt you. “Make disclosures even if you think your evaluations are unbiased.”
- Don’t assume the audience knows. “Don’t assume your followers already know about your brand relationships.”
Where it has to go — the part that matters here
This is the sentence to read twice:
“If making an endorsement in a video, the disclosure should be in the video and not just in the description uploaded with the video.”
In the video. Not the description. And the FTC is specific about why a description alone fails:
“Disclosures are likely to be missed if they appear only on an ABOUT ME or profile page, at the end of posts or videos, or anywhere that requires a person to click MORE.”
On YouTube, the description is behind “…more” for most viewers. On a phone, the affiliate line is very often below the fold. That’s the exact failure mode named in the guidance.
It also rules out saving it for the end:
the disclosure should be placed “with the endorsement message itself”
and warns:
“Don’t mix your disclosure into a group of hashtags or links.”
Which is precisely what a stack of affiliate links in a description does to it.
What this means for a faceless channel specifically
You have no presenter to say it casually on camera. So it has to be built into the two things you do control: the script and the on-screen text.
The FTC wants both, and explains the reasoning:
“Viewers are more likely to notice disclosures made in both audio and video. Some viewers may watch without sound and others may not notice superimposed words.”
For a synthetic-narration workflow that means:
- Write it into the script, so the voice actually says it. It costs you one sentence of narration, near the start, before the recommendation rather than after it.
- Superimpose it on screen at the same time, and leave it up long enough to read.
- Then also put it in the description — as a supplement, not the whole thing.
The good news: this is genuinely easy for a scripted format. You’re already writing every word. Adding a disclosure sentence to a template is a one-time change, and unlike a live presenter you will never forget to say it.
Wording that works
The FTC accepts plain language, and explicitly names some:
- “advertisement,” “ad,” and “sponsored”
- “Simple explanations like ‘Thanks to Acme brand for the free product’ are often enough if placed in a way that is hard to miss.”
- A hashtag like
#adis “fine (but not necessary)”
And names what to avoid:
“Don’t use vague or confusing terms like ‘sp,’ ‘spon,’ or ‘collab,’ or stand-alone terms like ‘thanks’ or ‘ambassador’”
Note that bare “thanks” fails. “Thanks to Acme for the free product” works because it states the relationship; “thanks to Acme” alone doesn’t.
The platform checkbox is not enough on its own
YouTube’s paid-promotion toggle is useful, but the FTC’s position is unambiguous:
“Don’t assume that a platform’s disclosure tool is good enough, but consider using it in addition to your own, good disclosure.”
Use it and disclose properly. Not instead.
One more rule that shapes what you can publish
“You can’t talk about your experience with a product you haven’t tried.”
This is why every article on this site states its basis up front — whether something is written from daily use, from a trial, or from documentation alone. If we haven’t run a tool at volume, we say so rather than implying experience we don’t have. That’s not just good manners; describing experience you didn’t have is the thing the rule prohibits.
Related
- Do you have to disclose an AI voice on YouTube? — a platform rule, distinct from this legal one
- Will YouTube demonetize a faceless channel?
Caveats: this is a reading of FTC staff guidance, not legal advice. The guidance page carries a November 2019 date and the Endorsement Guides have been revised since, so check the current text. The FTC also notes that U.S. law applies “if it’s reasonably foreseeable that the post will affect U.S. consumers” even when posting from abroad, and that foreign laws may apply too.