Disclosure and account risk

The disclosure obligation is yours, not theirs

Under the FTC Endorsement Guides and the ASCI guidelines, the duty to disclose a material connection falls on the endorser — the person whose post it is. The brand is exposed as advertiser. The mediator, sitting in the middle, is frequently neither.

That means the person legally on the hook for disclosure is the person with the least information about the rule, the least power to insist on it, and a direct financial incentive to skip it — undisclosed content performs better, and the brief you were sent may ask for exactly that.

"My mediator told me not to tag it" is not a defence. The obligation is not transferable by instruction. If a brief asks you to skip disclosure, the marketplace and the regulator hold your account responsible, not theirs.

What counts as a material connection

Any connection that could affect how much weight a reasonable person gives your review — disclosed, plainly, in the post itself:

• Being paid, in cash or in commission, for the post.
• Free product counts even where no cash changes hands. This is the misunderstanding behind most non-disclosure in this market — "they only sent me the product, they didn't pay me" is not an exemption.
• A discount, a reimbursement, or a buy-and-be-refunded arrangement.
• Being asked to buy the product with the promise of being paid back.
• Any campaign relationship with the mediator, even unpaid ones on future campaigns.

Your account is what is actually at risk — not the mediator's

Marketplace terms bind the account that posts the review, not the mediator who briefed it. Two of the largest platforms in this market say so directly:

• Amazon.in: "Accepting free products or compensation directly from sellers or brands in exchange for reviews is strictly prohibited" — the prohibition is written against the customer, and enforcement lands on the reviewing account.
• Flipkart reserves the right to "blacklist the customer from posting any further customer reviews", with a general power of "indefinite suspension of a User's account".

The mediator appears in neither sentence. The asymmetry is total:

And the failure compounds in a specific, common sequence: your account is banned, the review is deleted, the mediator says the deliverable was never provided, and the mediator does not reimburse you. You lose the product, the work, the account, and the money — the mediator loses nothing. This is what TrustDrive's DeliverableRemovedByPlatform report exists to record, and it is why the listing policy makes withholding reimbursement on this ground, without having said so in advance, a prohibited practice (P14).

Practices that put your account at risk

If a brief asks any of the following, it is putting your marketplace account — not the mediator's — at risk. Reporting one of these is the single highest-quality evidence in TrustDrive's compliance process, because a brand never sees the brief and a mediator will never volunteer it:

• Operating more than one marketplace account, including a family member's.
• Buying and refunding to manufacture a verified-purchase badge.
• A minimum star rating as a condition of being reimbursed.
• Posting a review before the product has actually arrived or been used.
• An explicit instruction not to disclose the connection.
• VPNs, device changes, or address rotation to avoid platform association.
• Review text supplied for you to post as your own genuine experience.

Questions to ask before you agree to a campaign

1. What is the order value, and am I fronting it myself?
2. When, specifically, do you reimburse — and what happens if that slips?
3. What happens to my reimbursement if the platform removes my review? Ask them to state it before you spend anything — TrustDrive publishes this as platformRemovalPolicy on a mediator's profile where they have stated it.
4. Are you asking me to skip disclosure, run more than one account, or do anything else on the list above? If yes, that is a reason to walk away, not a detail to negotiate.

Not in force yet. A per-platform, per-market library of copy-paste disclosure lines — the exact wording to put in a caption on each marketplace — is named in the plan and not yet written. What is above is the obligation and the risk, not a drop-in phrase for every surface.

What TrustDrive does and does not do about this

This guidance is free, always, for every influencer, on every listing — it is never paywalled, never suppressible by a mediator at any commercial tier, and never tuned down because it reduces how often someone messages a mediator. TrustDrive cannot make marketplace-review work safe for your account. It can make the risk visible, make a mediator's terms explicit, and record who actually reimbursed. That is a real contribution and it is not safety.

Related: the listing policy, and how to report a non-payment.