Affiliate Disclosures for AI Tool Reviews: FTC-Based Guide

The short answer

If a publisher can earn a commission from a recommended link, readers should be told plainly and close to the recommendation. A site-wide policy page is useful background, but it is not where a reader making a decision will look.

This guide applies the US Federal Trade Commission’s FAQ, “FTC’s Endorsement Guides: What People Are Asking,” to AI tool reviews. It is a practical reading of that guidance, not legal advice. The FTC itself says its staff guidance “doesn’t provide a safe harbor from potential liability,” and that the facts of each case matter. If your situation is complicated, ask a lawyer.

What the FTC guidance says

The FAQ addresses affiliate marketers directly. These are the points that matter most for review sites:

• Disclose clearly and conspicuously. An affiliate marketer earning commissions from retailer links should disclose that relationship clearly and conspicuously on the site, so readers can decide how much weight to give the endorsement. The FAQ offers sample wording: “I get commissions for purchases made through links in this post.”
• Closer is better. “The closer the disclosure is to your recommendation, the better.” When the review contains a clear disclosure and the reader can see the review and the link at the same time, a single disclosure may be adequate. If the two are separated, readers may not make the connection.
• The top and bottom of a page are weak spots. The FAQ says readers might overlook a disclosure at the very top of a page, outside the post, and may miss one at the bottom because many do not read to the end. A disclosure is more likely to be seen when it is very close to, or part of, the endorsement.
• Some labels are too vague. Readers might not understand that “affiliate link” means the person placing it is paid for purchases. A “buy now” button is not adequate. “Commissionable link” is probably not clear. “Paid link” right next to an affiliate link should be adequate.
• Links to disclosures are easy to skip. A button labeled DISCLOSURE or LEGAL that links to a full disclosure is called “easily avoidable” and not clear and conspicuous. A single disclosure on a home page is not sufficient either, because visitors may read individual reviews without seeing it.
• No special wording is required. The goal is to give readers the essential information in words that are easy to understand.
• Unpaid links need no disclosure. If you link to retailers only as a convenience and are not paid, there is no connection to disclose.
• Ads beside reviews. If it is obvious which items are paid ads, and selling ad space does not affect which products a site reviews, what it says, or the placement or prominence of its reviews, nothing more is needed.

One more point for publishers outside the United States. Answering a question from a video creator based in London, the FAQ says that if it is reasonably foreseeable that the content will be seen by and affect US consumers, US law would apply. It adds that the UK and many other countries have similar rules.

What this means for AI tool reviews

AI products create a few situations that general affiliate advice does not cover well.

Free or upgraded accounts

Vendors often supply a paid plan or extra credits for testing. The FAQ says the FTC Act applies when you receive free products or other perks with the expectation that you will promote or discuss the advertiser’s products. Treat a supplied subscription like a supplied product and say so: “The vendor provided a Pro account for this review.” If you were also paid, the FAQ is clear that saying only that you received something for free is not enough. You do not have to state the amount, but you should say you were paid.

Comparison tables and ranked lists

A table of tools with “Try it” buttons is where readers are most likely to click and least likely to read surrounding text. Place a short disclosure directly above the table, and state whether ranking positions are editorial or paid.

Long reviews

Disclose near the first link and again near the verdict, because many readers jump straight to it.

Newsletters and social posts

The FAQ says the same guidance applies anytime you endorse a product and get paid through affiliate links, including reviews on other sites and tweets. Each email or post that carries an affiliate link needs its own disclosure.

Wording: good and bad examples

Wording	Assessment
“We may earn a commission if you buy through links on this page.”	Our preferred form. It names the financial relationship in plain words.
“Paid link” placed right next to the link	The FTC FAQ says this should be adequate for the nature of the link.
“Affiliate link” alone	The FTC FAQ says readers might not understand that the publisher is paid.
“Commissionable link”	The FTC FAQ calls this probably not a clear disclosure.
“Buy now” button with no other text	The FTC FAQ says this would not be adequate.
A “Disclosure” link in the footer	The FTC FAQ calls a hyperlinked disclosure easily avoidable.

A placement checklist

This is the checklist we apply. It goes slightly further than the FAQ, on purpose.

1. A short disclosure appears before or alongside the first affiliate link or recommendation.
2. It uses the same size and contrast as body text, not a tooltip, a collapsed section, or a faded caption.
3. It is repeated near later recommendations on long pages and above comparison tables.
4. It names the relationship plainly: commission, payment, free access, or sponsorship.
5. Vendor-supplied accounts or credits are disclosed separately from commissions.
6. Sponsored placements are labeled as advertising and kept apart from editorial rankings.
7. A full affiliate policy is linked from the article and the footer as background, never as the only disclosure.

Disclosure does not fix a thin review

A clear disclosure tells readers about the incentive. It does not make the review useful. Explain the test date, plan, tasks, limitations, and who the product fits. Include non-affiliate alternatives when they are better for a meaningful group of readers. Our AI tool review methodology sets out how we do this, and our site-wide affiliate disclosure explains our policy.

A sponsored placement is paid exposure and should be labeled that way. Do not sell a ranking position while presenting it as an independent result. The FAQ’s answer on ad space is a useful line to hold: advertising is fine when it does not change what is reviewed, what is said, or where reviews appear.

The conclusion

The best affiliate page makes three things obvious: how the publisher may be paid, how the product was evaluated, and why the recommendation follows from the evidence. The FTC guidance points the same way, toward plain words placed where the reader decides. Clarity is both a compliance practice and a trust advantage.