Disclosure rules for a launch on X

What does the FTC actually require?

The current text is the FTC’s Guides Concerning the Use of Endorsements and Testimonials in Advertising, 16 CFR Part 255, revised in a final rule published in the Federal Register on 26 July 2023. Section 255.5 says a connection between the endorser and the seller must be disclosed when it might materially affect the weight or credibility of the endorsement and a significant minority of the audience would not understand or expect it. The Commission’s examples of material connections include a business, family, or personal relationship, monetary payment, free or discounted products even if no endorsement was required in return, early access, and the possibility of being paid or of winning something.

The same section says the disclosure does not have to include every detail, such as the dollar amount, but it does have to communicate the nature of the connection well enough for someone to judge it. “Clear and conspicuous” is the standard. A buried hashtag, a disclosure only on a linked site, or a label that sits where people do not look fails that standard even if the words are technically present.

Read the rule at the Federal Register notice (opens in a new tab) and at 16 CFR 255.5 (opens in a new tab). If your counsel reads them differently for your facts, their reading governs. Ours is a founder’s map.

What is X’s Paid Partnership label?

TechCrunch reported on 2 Mar 2026 (opens in a new tab) that X introduced a Paid Partnership label creators can apply when they post, including after the fact, so a sponsored post does not depend on a hashtag alone. X’s head of product, Nikita Bier, is quoted there tying the label to transparency and to federal rules. We tried to open X’s own help-center policy page and received a 403, so we are not quoting a policy PDF we did not read. Treat the news report as evidence the label exists, and confirm the current toggle in the product.

Doomers’ homepage (opens in a new tab) says every compensated post in its launches carries that label, that the requirement is written into the creator brief, and that a creator who will not tag does not run. There are, in their words, no exceptions. That is the clearest public operating rule we found among the firms in this set. It is a good rule to hand to any other agency, including us.

Who else on a launch has a connection to disclose?

• A creator who was paid, gifted the product, or given early access.
• An investor posting praise, when a reader would not already know they own the company. “Investor in the company” is a plain disclosure.
• An employee or advisor. The relationship is material if the reader might think they are a customer.
• A founder posting from their own account. People generally expect a founder to promote their company. The FTC’s “reasonably expected” idea is why a founder post is a different case from a stranger’s post. Do not apply that comfort to the stranger.

TLVC’s Helena write-up describes investors and founder friends quote-posting in the first hour, and the Mave write-up describes creators posting pre-order screenshots. Those are good distribution mechanics. They are also the moment to check who needed a label. The write-ups do not say what labels were used.

What should you ask an agency before launch day?

1. Which posts are paid, gifted, or otherwise connected, by name.
2. Whether each of those posts will use X’s Paid Partnership label, a text disclosure, or both.
3. What they do if a creator refuses. Doomers’ answer is that the creator does not run.
4. Whether your own investors have been told to disclose the relationship.
5. Who checks the live posts in the first hour and gets a missing label fixed. TechCrunch noted the X label can be added after posting. That is a repair, not a plan.