What are the FTC Endorsement Guides?
The FTC Endorsement Guides are the Federal Trade Commission's guidance on using endorsements and testimonials in advertising, published at 16 CFR Part 255 and last revised in 2023. They require endorsements to reflect honest opinions, any material connection to be clearly disclosed, and results claims to be backed up. For practices, they shape patient testimonials, reviews and influencer posts.
- Endorsements must reflect the endorser's honest opinion and real experience.
- Material connections (payment, free treatment, discounts, employment, family) must be clearly disclosed.
- A testimonial about results implies they are typical; if not, disclose what people generally get.
- A separate 2024 FTC rule bans fake reviews and some review suppression, with civil penalties.
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What the Guides say
The Guides explain how Section 5 of the FTC Act, which bans unfair or deceptive practices, applies to endorsements. An endorsement is any message consumers are likely to believe reflects the opinions or experience of someone other than the advertiser. That includes patient testimonials, star ratings, social posts by influencers, and statements by doctors or experts.
Key principles: endorsers must have actually used the service; the advertiser cannot say through an endorser anything it could not say itself; claims need substantiation; and a material connection that consumers would not expect must be disclosed clearly and conspicuously, close to the endorsement. Since 2009, advertisers cannot rely on "results not typical" disclaimers. If an ad features a patient's results, it should either reflect what people generally achieve or clearly disclose generally expected results. The 2023 revision added guidance on review procurement, fake reviews and platform tools.
In 2024 the FTC also finalized a separate rule on consumer reviews and testimonials, which allows civil penalties for things like fake or AI-generated reviews and certain review suppression.
How it applies to practice marketing
- Patient testimonials: use real patients, real words and results that reflect typical outcomes or include a clear disclosure.
- Incentives: if patients got anything for a review or video, disclose it. Platform rules may ban incentives entirely.
- Influencers and staff: paid or comped creators and employees must disclose the relationship in each post, not only in a bio.
- Before-and-after images: keep lighting, angle and editing honest; state rules may add requirements.
Also needed: HIPAA authorization from patients whose stories you use. See the influencer endorsement guide, the before-and-after compliance guide and review rules for practices.
Common mistakes and limits
Common problems include staff posting reviews of their own practice, offering discounts only for five-star reviews, showing the strongest result as if it were normal, and influencer posts with disclosures hidden in hashtags. The Guides themselves are not binding regulations, but the FTC uses them to judge deception, and the 2024 reviews rule does carry penalties.
State medical boards have their own testimonial rules, and some are stricter than the FTC. Check state rules and confirm sensitive campaigns with your compliance or legal team.
Related pages from the US team
Influencer endorsement FTC guide
Disclosure rules for creator partnerships.
Before-and-after photo compliance
Using result photos without misleading.
Patient reviews and FTC rules
How to request and use reviews.
US healthcare marketing glossary
Every term, defined in plain English.
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We benchmark your last 90 days, agree monthly goals with you, and track them live on Ichelon Agency OS with a report every Monday. Performance-Linked Payout Models are available. Our US leadership is based in Dallas, and strategy calls run in US business hours.
Common questions
Do the FTC Endorsement Guides apply to medical practices?
Yes. They apply to any business advertising in the US, including medical, dental and aesthetic practices. Patient testimonials, reviews, influencer posts and expert endorsements in practice marketing are all covered.
Can a practice offer patients a discount for leaving a review?
It is risky. Any incentive is a material connection that should be disclosed, and offering incentives only for positive reviews can be deceptive. The FTC's 2024 reviews rule bans incentives conditioned on review sentiment, and Google's policies discourage incentivized reviews.
Can a practice say "results not typical" under a testimonial?
Not as a safe harbor. Since 2009, the FTC has said a testimonial about results implies they are typical. If they are not, the ad should clearly disclose the results people can generally expect, and the practice should be able to support that claim.
Do influencers need to disclose free treatments?
Yes. A free or discounted treatment is a material connection. Under the FTC Endorsement Guides, influencers should disclose it clearly in each post, in plain words such as "I received this treatment free from the practice", where viewers will see it.
A note on this guide: it explains marketing practice, not legal advice. Rules on privacy, advertising and insurance change and vary by state, so confirm anything compliance-related with your own counsel.
Using testimonials or influencers in your marketing?
Book a 30-minute call. We'll review your testimonials, review requests and creator posts against FTC and state rules.