Module 2 - The 4 Ps Framework for Effective Disclosures

Introduction

Making a disclosure is not enough. The FTC requires that disclosures be “clear and conspicuous.” To help affiliates understand what this means, the FTC developed guidance around four key principles, commonly known as the “4 Ps”:

Prominence
Presentation
Placement
Proximity

This framework applies across all platforms and content types.

Source: FTC’s .com Disclosures guide - https://www.ftc.gov/tips-advice/business-center/guidance/com-disclosures-how-make-effective-disclosures-digital

The Clear and Conspicuous Standard

Legal Definition

A disclosure is “clear and conspicuous” when it is:

Difficult to miss (consumers are likely to notice it)
Easy to understand (in plain language)
Communicated in a way that allows consumers to process it before taking action

What This Means in Practice

The disclosure must be presented so that:

Ordinary consumers will see it
They will understand what it means
They will have this information before clicking or purchasing

A disclosure that requires effort to find or understand fails the clear and conspicuous test.

Prominence: Make It Noticeable

The Principle

Your disclosure must stand out and be easy to see. It should not be hidden, buried, or presented in a way that makes it easy to overlook.

Visual Prominence

Font Size:

Use the same size font as your main content
Larger is better than smaller
Never use text smaller than the product claims

Color and Contrast:

✅ Use contrasting colors that stand out from the background
✅ Dark text on light background or vice versa
❌ Light gray on white background
❌ Text that blends into images

Formatting:

✅ Bold or highlighted text draws attention
✅ Boxes or borders can highlight disclosures
❌ All caps in tiny font is not prominent
❌ Buried in walls of text

Examples of Good Prominence

Blog Post - High Prominence:

[Colored box at top of post]
━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━
DISCLOSURE: This post contains affiliate links.
I earn commission on purchases at no extra cost to you.
━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━

Social Media - Clear and Prominent:

#ad - AFFILIATE DISCLOSURE
I earn commission through these links.

[rest of caption]

Examples of Poor Prominence

Hidden in Footer:

[Entire blog post of 2000 words]

[Footer in 8pt gray text]
This site may contain affiliate links

Buried in Text:

I've been using this amazing product for months and I absolutely
love it and think you should try it too because it's the best
thing ever and by the way I earn a commission if you buy but
seriously it's great and you'll love it too I promise.

Unreadable:

[Light yellow text on white background]
affiliate link

Platform-Specific Prominence

Instagram/TikTok:

Place disclosure in first 1-2 lines of caption
Use clear hashtags like #ad or #affiliate
Don’t bury in a list of 20 hashtags

YouTube:

Verbal disclosure in first 30 seconds (clear audio)
Visual overlay on screen for at least 3-5 seconds
Large enough text to read on mobile devices

Blog/Website:

Disclosure at or near the top, before main content
Can use colored box or border to highlight
Repeated near affiliate links if post is long

Presentation: Use Clear Language

The Principle

Consumers must understand what the disclosure means. Use plain, straightforward language that clearly communicates your financial relationship.

Effective Language

Clear and Direct:

✅ “I earn a commission if you purchase through this link”
✅ “I’m paid to promote this product”
✅ “This is an affiliate link”
✅ “I receive compensation for these recommendations”

Short Hashtags (Social Media):

✅ #ad
✅ #affiliate
✅ #sponsored
✅ #partner (only if you explain it means paid)

Ineffective Language

Too Vague:

❌ “Thank you to [Brand] for supporting this content” (Are they paying you?)
❌ “In partnership with [Brand]” (Does that mean money?)
❌ “This is a collab” (What kind of relationship?)
❌ “Ambassador for [Brand]” (Paid or unpaid?)

Too Technical:

❌ “This contains CPA offers”
❌ “Performance marketing links included”
❌ “Monetized through affiliate networks”

Ambiguous Hashtags:

❌ #sp (What does this mean?)
❌ #spon (Is this a typo or abbreviation?)
❌ #collab (Paid or unpaid?)

The “Ordinary Consumer” Test

Ask yourself: Would someone unfamiliar with affiliate marketing understand that you’re getting paid?

Good Test Example:

“I earn commission on purchases” - Yes, anyone would understand
“Thanks to Brand for partnering” - No, unclear if paid

Avoiding Consumer Confusion

Don’t use language that could mislead:

❌ “This is not a paid promotion” (if you’re earning commission, it IS paid)
❌ “I’m sharing this because I love it” (True, but also disclose if paid)
❌ “No one paid me to say this” (Commissions count as payment)

International Audiences

If your audience includes non-native English speakers:

Use simple words
Avoid idioms and slang
Consider translations for primary non-English audiences

Placement: Where People Will See It

The Principle

Disclosures must be placed where consumers are likely to see them before taking action. They should not require additional effort to find.

Before the Action

The disclosure must appear BEFORE:

The affiliate link
The product recommendation
The call to action (CTA)
The purchase decision

Wrong Order:

Check out this amazing product! [LINK] Click here to buy now!

Oh by the way, I earn commission on this.

Right Order:

Disclosure: I earn commission on this product.

Check out this amazing product! [LINK]

Platform-Specific Placement

Blog Posts:

✅ At the very top, before any product discussion
✅ Can repeat near individual affiliate links in long posts
❌ Only in footer or sidebar
❌ On a separate “Disclosures” page only

Social Media Posts:

✅ First 1-2 lines of caption (before “read more” cutoff)
✅ In the caption itself, not just comments
❌ Buried after 10 lines (hidden by “read more”)
❌ Only in comments section

Videos:

✅ Verbal disclosure in first 30 seconds
✅ Visual text overlay at the beginning
✅ Also in video description
❌ Only at the end of video
❌ Only in description (viewers may not read it)

Email:

✅ In email body before first affiliate link
✅ Clear and prominent in email text
❌ Only in email footer
❌ Requiring click to another page

Podcasts:

✅ Verbal disclosure before or during product discussion
✅ Clear statement of compensation
❌ Buried in the middle of ad read
❌ Only in show notes (listeners may not check)

The “Unavoidable” Test

Consumers should encounter the disclosure without:

Scrolling down
Clicking links
Hovering over elements
Expanding collapsed sections
Reading fine print

If consumers can miss the disclosure while viewing your content, the placement is inadequate.

Multiple Products

When recommending multiple products in one piece of content:

Disclose at the top that the post contains affiliate links
Optionally mark individual links (e.g., “affiliate link” next to each)
Don’t make consumers guess which links are affiliate

Example:

DISCLOSURE: This post contains affiliate links (marked with *).
I earn commission on purchases.

I recommend three tools:
- Tool A [link]* - affiliate
- Tool B [link] - not affiliate
- Tool C [link]* - affiliate

Proximity: Close to the Claim

The Principle

The disclosure must be near the affiliate link or product claim so consumers make the connection between the disclosure and the specific product you’re promoting.

Visual Proximity

Close in Space:

Disclosure should be in the same visual field as the affiliate link
Ideally, immediately before or next to the link
Should not require scrolling to see both disclosure and link

Good Proximity Example - Blog:

DISCLOSURE: Affiliate link below - I earn commission

[2 sentences about product]

Check it out here: [AFFILIATE LINK]

Poor Proximity Example - Blog:

DISCLOSURE: This blog contains affiliate links

[15 paragraphs of content]
[Multiple topics discussed]
[Scrolling required]

Here's the product: [AFFILIATE LINK]

Temporal Proximity

For video and audio content:

Disclosure should be close in time to the product mention
Ideally within the same segment or scene
Don’t disclose at the start and then mention product 20 minutes later

Good Temporal Proximity - Video:

"Before I show you this product, quick disclosure:
This is an affiliate link. I earn commission if you purchase.
Now, here's why I love this product..."

Poor Temporal Proximity - Video:

[Minute 1] "This video has affiliate links"
[Minutes 2-20] Other content
[Minute 21] "Buy this product!" [shows link]

Context Connection

Consumers must be able to connect the disclosure with the specific claim or link:

If you have multiple products, they should know which are affiliate
If mixing paid and unpaid recommendations, clarify which is which
Don’t make them guess

Long-Form Content

For lengthy blog posts or videos:

Include disclosure at the top
Consider repeating disclosure near each affiliate link
Use visual or verbal cues (e.g., “Remember, this is an affiliate link”)

Combining the 4 Ps

Evaluation Checklist

For any disclosure, ask these questions:

Prominence:

Is it noticeable and easy to see?
Does it stand out from surrounding content?
Is the font size adequate and readable?

Presentation:

Is the language clear and unambiguous?
Would an ordinary consumer understand I’m being paid?
Did I avoid vague or technical terms?

Placement:

Is it before the affiliate link or claim?
Is it where consumers are likely to look?
Does it require no additional effort to find?

Proximity:

Is it close to the affiliate link in space or time?
Can consumers easily connect the disclosure to the product?
Is the relationship obvious?

If you answer “no” to any question, revise your disclosure.

Common Scenarios

Scenario 1: Instagram Post

Bad Disclosure:

Caption:
Love this new skincare routine! My skin has never looked better!
So glowy and smooth! You need to try it! Link in bio!

#skincare #beauty #glowingskin #selfcare #loveit #amazing
#beautiful #life #instagood #photooftheday #happy #ad

Why It Fails:

Placement: #ad is last hashtag (buried)
Proximity: Far from the product mention
Presentation: Buried among unrelated hashtags

Good Disclosure:

Caption:
#ad | AFFILIATE DISCLOSURE: I earn commission through my link.

Love this new skincare routine! My skin has never looked better!
Check out my link in bio.

Why It Works:

Prominence: First line, clear hashtag
Presentation: Clear language
Placement: Before product discussion
Proximity: At the start, connected to link mention

Scenario 2: YouTube Video

Bad Disclosure:

[20 minute video about product]
[Minute 19:30] "Oh, and by the way, this is an affiliate link"

Description:
[Long description]
[Paragraph 5] Contains affiliate links

Why It Fails:

Placement: Disclosure at end of video
Temporal Proximity: Far from main product discussion
Reliance on description: Many viewers won’t read it

Good Disclosure:

[First 30 seconds]
Verbal: "Quick disclosure before we start: This video contains
affiliate links. If you purchase through my links, I earn a
commission at no extra cost to you."

Visual: [Text overlay for 5 seconds]
"AFFILIATE LINKS - I EARN COMMISSION"

Description:
AFFILIATE DISCLOSURE
This video contains affiliate links. When you purchase through
these links, I earn a commission.

Product Links:
• Product Name [link] - affiliate

Why It Works:

Prominence: Verbal and visual at start
Presentation: Clear, simple language
Placement: Before product discussion
Temporal Proximity: At the beginning

Scenario 3: Blog Post

Bad Disclosure:

[Blog Header]
[Navigation Menu]
[Main Content - 2000 words about product]
[Multiple "Buy Now" affiliate links throughout]

[Footer]
Disclosure: Some posts contain affiliate links. See our Privacy
Policy for more information.

Why It Fails:

Placement: Footer only (readers may never scroll there)
Presentation: Vague (“some posts” - is this one included?)
Requires clicking to another page
Proximity: Far from affiliate links

Good Disclosure:

[Blog Header]
[Navigation Menu]

━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━
DISCLOSURE: This post contains affiliate links.
I earn commission if you purchase through these
links at no extra cost to you.
━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━

[Main Content]

Today I'm reviewing Product X...

[After reviewing]
If you want to try it, check it out here:
[AFFILIATE LINK] (affiliate)

Why It Works:

Prominence: Highlighted box at top
Presentation: Clear statement of commission
Placement: Before any product discussion
Proximity: At top, and marked near link

Special Considerations

Mobile Devices

Most consumers view content on mobile devices. Ensure:

Text is large enough to read on small screens
Disclosures appear above the fold (no scrolling)
Visual prominence works on mobile
Social media “read more” doesn’t hide disclosure

Accessibility

Consider users with disabilities:

Screen readers should be able to read disclosures
Don’t rely solely on color to convey disclosure
Provide text alternatives for visual disclosures
Ensure sufficient color contrast

International Audiences

If you have global followers:

Use universally understood terms
Consider language barriers
Some countries may have stricter rules

Platform Limitations

Some platforms have character limits or format restrictions:

Use concise disclosures (#ad, #affiliate)
Prioritize disclosure over other content
Use platform tools (e.g., Instagram’s “Paid Partnership” tag) but don’t rely on them alone

Summary

The 4 Ps Quick Reference

Prominence: Noticeable, clear font, contrasting colors
Presentation: Plain language, unambiguous, easy to understand
Placement: Before the link, where people look, no additional effort
Proximity: Close to claim, visual/temporal connection, obvious relationship

Key Takeaways

All four principles must be met for effective disclosure
The “clear and conspicuous” standard is high
When in doubt, be more prominent and clear
Test your disclosures: Would an ordinary consumer notice and understand?
Err on the side of over-disclosure rather than under-disclosure

Next Module

In Module 3, you’ll learn platform-specific disclosure requirements and see detailed examples for blogs, social media, videos, and more.

Module 2 Complete

You now understand the 4 Ps framework for creating effective disclosures.