# What a Clear Disclosure Looks Like in a Short Comment

> A clear disclosure in a comment is one plain sentence inside the comment itself, placed before or in the sentence that names the product, written in the thread's language, saying what the connection is: "I'm the founder of Acme." FTC guidance asks that it be hard to miss and easy to understand. A profile line, a later reply or a platform tag alone falls short.

URL: https://agentagency.si/blog/clear-disclosure-in-a-comment · Updated: 2026-10-22

## The six checks a comment has to pass

Two US texts define a clear and conspicuous disclosure. The FTC's [Endorsement Guides](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-B/part-255) (16 CFR Part 255, current text from July 26, 2023) say it must be easy to notice and easy for ordinary people to understand, and that on social media and the web it should be unavoidable. The [Rule on Consumer Reviews and Testimonials](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-D/part-465) (16 CFR Part 465, August 22, 2024) spells the same idea out in a list. Neither has a section on forum comments, so the table below reads both for the case this page is about: a reply of two to five sentences in a thread.

**What clear and conspicuous means for one comment**

| Check | What it means in a comment | Where it comes from |
| --- | --- | --- |
| 1. It is in the comment | Not in your bio, your username, an earlier comment or a reply further down. | Part 255, section 255.0 Example 9(i); the FTC's Q&A on profile pages and on disclosures placed in comments |
| 2. It comes before or with the mention | The first sentence, or the sentence that names the product. Not the last line of a long reply. | The FTC's Q&A says a disclosure in the middle or at the end of a post is easier to miss |
| 3. It says what the connection is | "I work at Acme" or "I built Acme", not "I'm affiliated". | Section 255.5(a): the disclosure must tell readers the nature of the connection |
| 4. It is in the thread's language | A German thread gets a German disclosure. | Section 255.0 Example 11(i); section 465.1(c)(5) |
| 5. Nothing else in the comment undercuts it | No "just a happy user" or "not sponsored" next to it. | Section 255.0(f); section 465.1(c)(7) |
| 6. It works on a phone | Visible without tapping "more" or expanding the comment. | Section 255.0 Example 9(ii) and Example 11(ii); section 465.1(c)(4) and (c)(6) |

Check 3 is the easiest one to get half right. Section 255.5(a) says the disclosure does not need every detail, but readers must be able to judge how much the connection matters. "Affiliated" could mean anything from founder to a friend of a friend. The FTC's [Q&A on the Guides](https://www.ftc.gov/business-guidance/resources/ftcs-endorsement-guides-what-people-are-asking) makes the same point about tags: readers are unlikely to read #employee as "works for this company", while "I work for XYZ" or "my employer's" in the sentence itself is clear.

## Six drafts, rewritten

Each draft below was written by someone connected to the product. The rewrites keep the useful part of the answer and fix the one thing that made the disclosure fail.

**Comment drafts and their fixes**

| Draft | What fails | Rewrite |
| --- | --- | --- |
| "Been on Acme for a year and it fixed this for me." (posted by the founder) | Reads as an outside user. Section 465.5(a) makes it unfair or deceptive for an officer or manager to write a consumer review or testimonial about their business without clearly disclosing that relationship. | "I built Acme, so weigh this accordingly: it was made for exactly this case." |
| A 150-word answer that ends with "(full disclosure: I'm on the team)" | Check 2. The recommendation has done its work before the reader reaches the disclosure. | Move the line to the top: "I'm on the Acme team. For what you describe, here's what I'd try first." |
| "Acme handles this well #affiliated" | Check 3. The tag does not say what the connection is. | "I work at Acme, which makes this, and it handles the case well." |
| A Spanish thread, answered in Spanish, with "Disclosure: I work there" in English | Check 4. Readers of the thread may not read the English line. | Write the disclosure in Spanish, in the same sentence as the product name. |
| "Not sponsored, I just like Acme." (from a contractor Acme pays) | Check 5. The comment states the opposite of the connection. | "Acme pays me to help with its community, so I'm not neutral here." |
| "See my profile for who I am." | Check 1. The reader has to click to learn it, which section 465.1(c)(4) says is not clear and conspicuous. | Put the fact in the comment: "I co-founded Acme." |

For more wording by role (employee, agency, affiliate link, friend of the founder), see the [disclosure templates](https://agentagency.si/guides/reddit-disclosure-templates). For what else makes a reply read as an ad, see [how to write a Reddit comment that is not spam](https://agentagency.si/guides/how-to-write-a-reddit-comment-that-is-not-spam).

## Situations that only come up in threads

### Your second and third replies

Someone asks a follow-up and you answer again, naming the product. The FTC's Q&A says that if one post about a brand needs a disclosure, the others probably do too, because you can't assume readers saw the earlier ones. A reply can be linked to, quoted or reached from search without the rest of the thread. A short repeat such as "(I work on it, as above)" is enough.

### Adding the disclosure in an edit

If you forgot, edit the comment and put the line at the top, not at the bottom. Everyone who read it before the edit saw no disclosure, so the habit to build is writing it in before you post.

### Comments that compare you with a rival

The FTC's Q&A says someone paid to endorse a brand should disclose that deal when criticizing a competitor, because it changes how much weight readers give the criticism. Section 255.0 Example 12 notes that a paid negative statement about a competitor is not an endorsement under the Guides but can still be deceptive. Disclose first, and keep claims about other products to what you can show.

### Reddit's Brand Affiliate tag

Reddit's help center describes a [Brand Affiliate tag](https://support.reddithelp.com/hc/en-us/articles/23972085214484-What-s-a-brand-affiliate-tag) (article updated February 22, 2024) that redditors can choose to put on posts or comments that are incentivized or have commercial intent. The same article says you remain responsible for following the law, including any required disclosures. The FTC's Q&A says a platform's built-in tool is not automatically an effective disclosure, and section 255.0 Example 9(iii) describes a platform label that was easy to miss. Use the tag if you like, and still write the sentence.

Reddit's sitewide [rules](https://redditinc.com/policies/reddit-rules) do not prescribe wording. Rule 5 asks users not to intentionally mislead others or impersonate anyone deceptively, and Rule 2 asks for authentic participation and community rules followed. A disclosure does not make a post welcome in a subreddit that bans promotion; see [Reddit's self-promotion rules](https://agentagency.si/guides/reddit-self-promotion-rules).

### Replies from a clearly named brand account

Section 255.0(b) defines an endorsement as a message readers are likely to take as the view of someone other than the advertiser. A reply from an account plainly named for your company is the company speaking, much like the spokesperson in Example 3, so on our reading the endorsement disclosure question mostly falls away. It returns when the account looks like a person. [Brand account or founder account](https://agentagency.si/guides/brand-account-or-founder-account) covers that choice.

### Replies drafted with AI

Part 255 and Part 465 do not mention artificial intelligence. They ask who the reader thinks is talking and whether what they say is true. A drafted reply posted from a disclosed founder account is the founder speaking, and the same one-sentence disclosure covers it. A drafted review or testimonial that claims experience nobody had is the kind of misrepresentation section 465.2(a) prohibits when a business writes it, and no disclosure fixes that. [FTC disclosure rules for brand posts and AI replies](https://agentagency.si/blog/ftc-disclosure-for-ai-agents-on-social) goes further into both texts.

## If your readers are in the EU

The EU's Unfair Commercial Practices Directive (2005/29/EC) treats it as a misleading omission when a trader fails to make the commercial intent of a practice clear, if the context does not already show it and the omission is likely to change what the average consumer decides ([Article 7(2)](https://www.legislation.gov.uk/eudr/2005/29/article/7/adopted)). [Annex I](https://www.legislation.gov.uk/eudr/2005/29/annex/I/adopted) lists practices that are unfair in all circumstances. Point 11 covers paid promotion presented as editorial content without making the payment clear. Point 22 covers a trader who falsely claims, or gives the impression, of not acting for business purposes, or who poses as a consumer. A founder recommending their own product while sounding like a customer is, on our reading, closest to point 22.

The European Commission's [Legal Brief #6](https://commission.europa.eu/system/files/2023-10/Legal%20brief%206.pdf) for its Influencer Legal Hub adds a practical line: authorities do not accept disclosures that make people scroll or click "read more", and a label at the end of a long caption may go unseen. It also notes that some countries have more specific requirements and that national authorities may expect different things; see [EU disclosure rules for brand posts](https://agentagency.si/guides/eu-disclosure-rules-for-brand-posts).

> **Note:** This page explains public guidance as of 2026-10-22. It is not legal advice. If a campaign is large or the connection is unusual, ask a lawyer who knows the countries your readers are in.

## Where Agent Agency fits

Agent Agency drafts and posts replies from accounts you connect, guided by the Product DNA you approve. In Approve mode every reply waits for you, so you can run the six checks above before anything goes out. You, as the operator, decide what each reply says, and the platform's rules and the law require disclosing a material connection. [How it works](https://agentagency.si/how-it-works) has the details.

## Questions

### Does the disclosure have to be the very first words of a comment?

No text sets a word position. The FTC's Q&A says disclosures in the middle or at the end of a post are easier to miss, and the EU's Legal Brief #6 warns about labels at the end of long captions. In a short comment, the first sentence or the sentence that names the product is the safe place.

### Is #ad enough in a Reddit or X comment?

The FTC's Q&A says hashtags are nothing special and that starting a post with Ad or #ad would likely work for paid content. For a founder or employee, #ad does not say what the connection is. A plain sentence such as I built this or I work at Acme tells readers more in about as many characters.

### Do I need to disclose if my username is my company name?

If the account is plainly the company, readers know who is talking, so it reads as the brand's own message rather than an endorsement. A username that only hints at the company, or a personal account with the company in the bio, is not enough: the FTC treats profile-only disclosures as easy to miss.

### Does using Reddit's Brand Affiliate tag replace a written disclosure?

Reddit describes the tag as an option and says users stay responsible for any disclosure the law requires. The FTC's Q&A says a platform tool is not automatically effective. Using both costs one sentence and removes the doubt.

Join the waitlist, approve your Product DNA, and choose Approve mode to read every reply before it goes out. [Join the waitlist](https://agentagency.si/waitlist)

## Sources

- [16 CFR Part 255: Guides Concerning Use of Endorsements and Testimonials in Advertising (eCFR)](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-B/part-255), accessed 2026-10-22
- [16 CFR Part 465: Rule on the Use of Consumer Reviews and Testimonials (eCFR)](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-D/part-465), accessed 2026-10-22
- [FTC's Endorsement Guides: What People Are Asking](https://www.ftc.gov/business-guidance/resources/ftcs-endorsement-guides-what-people-are-asking), accessed 2026-10-22
- [Reddit Help: What's a brand affiliate tag? (updated February 22, 2024; read via the Wayback Machine snapshot of 2026-08-10)](https://support.reddithelp.com/hc/en-us/articles/23972085214484-What-s-a-brand-affiliate-tag), accessed 2026-10-22
- [Reddit Rules](https://redditinc.com/policies/reddit-rules), accessed 2026-10-22
- [Directive 2005/29/EC (Unfair Commercial Practices Directive), Article 7, as adopted](https://www.legislation.gov.uk/eudr/2005/29/article/7/adopted), accessed 2026-10-22
- [Directive 2005/29/EC (Unfair Commercial Practices Directive), Annex I, as adopted](https://www.legislation.gov.uk/eudr/2005/29/annex/I/adopted), accessed 2026-10-22
- [European Commission Influencer Legal Hub, Legal Brief #6: How to disclose advertising on social media](https://commission.europa.eu/system/files/2023-10/Legal%20brief%206.pdf), accessed 2026-10-22

## Related

- [How to Disclose Your Affiliation on Reddit](https://agentagency.si/guides/reddit-disclosure-templates)
- [FTC Disclosure Rules for Brand Posts and AI Replies on Social Media](https://agentagency.si/blog/ftc-disclosure-for-ai-agents-on-social)
- [Reddit Self-Promotion Rules: What Reddit Actually Says](https://agentagency.si/guides/reddit-self-promotion-rules)
- [EU and UK Disclosure Rules for Brand Posts in Online Communities](https://agentagency.si/guides/eu-disclosure-rules-for-brand-posts)
- [How to Write a Reddit Comment That Isn't Spam When You Work on the Product](https://agentagency.si/guides/how-to-write-a-reddit-comment-that-is-not-spam)
- [Reddit and X Community Marketing for Agencies](https://agentagency.si/for/marketing-agencies)