What Is The FTC Checklist For A med spa?

What Is The FTC Checklist For A med spa. Most small owners assume this is an influencer problem. It is not. The penalty is $53,088 per violation and each non-compliant post counts separately.

The rule, and why it applies to you

Most small owners assume this is an influencer problem. It is not, and that assumption is exactly why small operators get caught.

If you have a material connection to something you recommend — a commission, a free product, a relationship — you have to disclose it. There is no revenue threshold and no exemption for being new.

The penalty is $53,088 per violation, and each non-compliant post counts separately. That figure is not there to frighten you. It is there because most people reading this have never checked.

I am not a lawyer and this is not legal advice. What follows is the published FTC guidance and the documented penalties, which are matters of public record. How any of it applies to your specific business is a question for somebody qualified to answer it, and if you are running affiliate links or testimonials at any scale, that conversation is worth having.

The compliance checklist

Print this, or copy it somewhere you will find it. It is the shortest version of everything above.

The specifics

**Is the disclosure above the endorsement**, not below it and not in the footer?

**Is it in plain language** a normal person understands, rather than 'commissionable link'?

**Is it text**, not an image? Screen readers cannot read graphics and the FTC expects text.

**Does it state the fact** rather than hedging? 'Contains affiliate links', not 'may contain'.

**Are your reviews real**, from real customers who actually used the thing?

**Are incentivised reviews disclosed**, including free products of any value?

**Are insider reviews labelled** — employees, family, anybody with a financial interest?

**Are you leaving the negative reviews up?** Suppression is an enforcement priority.

**If AI wrote it, does anybody know?** Substantive AI generation should be disclosed.

**Are you using AI-generated testimonials?** Stop. Disclosure does not make those compliant.

What this means for a med spa

For a med spa the exposure is usually in three places, and none of them feel like wrongdoing from the inside.

**The testimonials page.** If any of those came from an employee, a friend, or somebody who got something in exchange, the relationship needs disclosing.

**The reviews.** If the bad ones quietly disappear, that is suppression, and it was one of the four things the FTC flagged in its December 2025 warning letters.

**The affiliate links.** If you recommend tools and earn from them, the disclosure has to be above the recommendation and in plain language. The footer does not count.

Fixing all three is an afternoon of work and it removes an entire category of risk.

What I do on this site, and why

Every review I publish contains an affiliate disclosure at the top, before the recommendation, in plain language. That is not generosity. It is the rule.

I also state plainly where the product I earn nothing from is the better choice. That is not required by the FTC. It is required by anybody who wants to be believed.

And I do not publish testimonials I did not receive, or reviews written by anybody with a stake. If a case study appears on this site, it is because somebody gave me real numbers.

The reason to do all of this is not fear of a fine. It is that an audience which suspects you are for sale stops being worth anything, and that loss is permanent in a way a penalty is not.

Where to start, this week

Look at your own site with fresh eyes. Where is the disclosure? Is it above the recommendation or below it? Could somebody miss it?

Read your testimonials page honestly. Who wrote those? Did anybody get anything?

Check whether you have ever deleted a negative review because it was negative.

And if you use AI to write content that recommends things, decide now how you will handle that, because the FTC established a dedicated AI enforcement unit in January 2026 and this is the direction the scrutiny is heading.

None of that costs money. All of it is worth an afternoon.

Why knowing is not enough

The obstacle is rarely knowledge. Most owners broadly understand that disclosure exists. What they have never done is check whether theirs actually complies.

Part of it is that nothing forces you to. Nobody sends a reminder. So it waits behind whatever is loudest that day, and it can wait for years.

And part of it is that a footer disclosure feels like it counts. It does not, and finding that out from an enforcement letter is an expensive way to learn it.

So make it deliberate. Put an hour aside. It is genuinely an hour.

An honest word about the risk

I am not going to pretend the FTC is likely to come after a business doing $4,000 a month. It probably is not.

But enforcement is frequently triggered by consumer complaints rather than by proactive investigation, which means it does not depend on your size. It depends on whether somebody is annoyed with you.

And the reputational cost lands whether or not a penalty does. A public accusation that you hid a paid relationship damages the trust you spent years building, and that damage does not have a payment plan.

So do it properly because it is cheap, not because you are afraid. The version where you are transparent and slightly less slick converts better anyway.

The timeline, so you can see where this is heading

The core principle has not changed since 1980. A material connection between somebody endorsing a product and the business behind it must be disclosed, so that consumers can weigh the endorsement knowing what sits behind it.

What has changed is scope and enforcement. The Endorsement Guides were revised in June 2023, broadening the definition of endorsement and material connection in ways that capture content most small operators would never have thought of as advertising.

The Consumer Review Rule took effect in late 2024, addressing fake reviews, incentivised testimonials, and the suppression of negative feedback.

In March 2025 the FTC published staff guidance specifically on the use of AI in advertising. In December 2025 it sent warning letters to ten companies. In January 2026 it established a dedicated AI enforcement unit, and the maximum penalty rose to $53,088 per violation.

None of that is speculation. It is the published record, and the direction is unambiguous.

Why the honest version converts better anyway

Here is the part that gets lost in the compliance conversation. Being transparent about a paid relationship does not damage the recommendation. It strengthens it.

A reader who can see that you earn from a link, and who watches you say plainly that a competitor is better for their situation, learns that you can be trusted. That trust is what makes the next recommendation land.

The people who hide the relationship are protecting a short-term conversion rate at the cost of the only asset that compounds. And readers are considerably better at detecting it than most publishers assume.

So do it properly because it works, not merely because it is required. The compliance is a by-product of the honesty rather than the reason for it.

What people ask me

How long before this starts working?

Longer than most people hope and sooner than most people fear. Give it a few months of steady effort rather than a few weeks, and judge it on whether enquiries are trending up rather than on any single week.

Do I need to spend money to start?

No. The highest-leverage steps here are free, and they are the ones almost nobody does. Tools help you measure and move faster. They do not do the work.

What if I have no time?

Then pick one thing from this and do it properly rather than five things badly. One change that actually happens beats a list you never start.

Is AI going to replace this work?

Not the work itself. It is genuinely useful for the repetitive parts around the work, and that is where the hours come back. The judgment stays yours, and that is what you are being paid for.

Affiliate Disclosure: This article uses affiliate links and may earn a commission from certain links, at no extra cost to you. Opinions expressed are our own.