> A provenance check for creators before a sponsorship: the archive, the audience, the disclosures, the claims, and what the FTC holds the brand responsible for.
>
> Source: https://gerriscorp.com/guides/vet-an-influencer/ · Updated 2026-10-24 · By Chris Abraham, Gerris Corp

# How to vet an influencer or creator before your brand pays them

By [Chris Abraham](https://gerriscorp.com/about/) · Published October 24, 2026

On Edelman's digital public affairs team in Washington, part of my job was checking online voices before a client went anywhere near them. The question was always the same: has this person said what they say now, to real people, for years, before anyone paid them to say it? The tools have changed since then. Follower counts are cheaper to fake, AI can generate a face and a posting history, and the FTC now has a rule with civil penalties attached. The question hasn't changed at all, and it still takes an afternoon of reading to answer.

## What the FTC expects from the brand

Two federal documents set the terms for a US sponsorship.
- **The Endorsement Guides (16 CFR Part 255), revised in 2023.** A creator you pay, or send free product, has a material connection that must be disclosed clearly and conspicuously in each post. The FTC's guidance says advertisers stay responsible for what endorsers say on their behalf, even when an outside agency runs the program, and should have "reasonable programs in place to train and monitor members of their network."
- **The Consumer Reviews and Testimonials Rule (16 CFR Part 465).** Announced August 14, 2024, published in the Federal Register on August 22, and in force since October 21, 2024. Among other things it bans selling or buying "fake indicators of social media influence, such as followers or views generated by a bot or hijacked account," where the buyer knew or should have known they were fake and used them to misrepresent influence for a commercial purpose.

The fake-followers ban lands on whoever bought them, usually the creator. The Endorsement Guides land on you. A brand that signs a creator with an inflated audience and a habit of unlabeled ads has bought both problems at once, which is why the checking happens before the contract.

## Read the archive first

The single most useful test is time. Scroll back two or three years on every platform the creator uses and read what they posted before your category paid them. A home cook who has been arguing about cast iron since long before any cookware brand called is a different proposition from an account that discovered cast iron the month a sponsor did.
- Check the account's age, its earlier names, and whether it was repurposed from a different topic.
- Look up their website or newsletter in the [Wayback Machine](https://web.archive.org/) to see what it said in earlier years, including anything they've since deleted.
- Search their name and handle with the category terms. Long, specific posts on old forums, Reddit threads, and podcasts are the strongest proof of a real interest.

## Read the audience, not the follower count

Real audiences answer back in particulars. They ask where the jacket came from, argue with the recipe, mention their own kids by name. Bought audiences leave short, interchangeable praise, emoji strings, and comments that would fit under any post on any account.
- Read the comments on a dozen posts, sponsored and unsponsored, and note how many could only have been written by someone who watched or read the post.
- Look for sudden jumps in followers that no viral post explains. Most analytics tools show growth history; ask the creator for screenshots from their own dashboards if you can't see it.
- Ask for audience location and age from the platform's native analytics. A creator pitched to US buyers whose audience sits mostly elsewhere isn't a fit, however large it is.
- Compare views to followers over time. Healthy accounts vary post to post. Numbers that never move are as suspicious as numbers that leap.

## Check who else has paid them

A creator's past sponsorships tell you how they'll handle yours. Find the posts that were clearly paid and see whether each one carried a clear disclosure at the start, where viewers would see it, or a buried tag at the end of a long caption. The FTC's guidance treats a disclosure tucked into comments or behind a "more" link as inadequate. Someone who hid the last brand's ads will hide yours, and your name is the one that ends up in the warning letter.

Note competitors in the list too. A creator who promoted three rival products this year can still be honest, but your audience will notice, and so will you when the next one pays more.

## Read the claims they've made before

The advertiser is answerable for deceptive claims an endorser makes about the product. So read what the creator has said about earlier sponsors: health and weight-loss promises, income claims, "cured my" stories, financial tips. A creator who made unsupportable claims for a supplement brand will improvise about yours. Health, money, and children's products deserve the closest reading, and the FTC's own guidance scales the monitoring it expects with the risk of harm.

## Confirm the person exists

Synthetic personas are cheap now. Run the profile photo and a few post images through a reverse image search to make sure they aren't lifted from someone else or generated. Look for the creator on video, speaking unscripted, in more than one setting. Check that the business details on a media kit, the company name, the address for contracts, the payment details, match each other and match a real registration. Pay a person or a registered company you've identified, never a stranger's account on a payment app.

## See what search and AI already say

Search the creator's name with "scam," "lawsuit," "apology," and "controversy," and read past the first page. Then ask ChatGPT, Gemini, Claude, and Perplexity who this person is, and follow every source they cite. Those answers are what your customers will read when your partnership announcement makes them curious. If an assistant repeats an old controversy, decide now whether you can live beside it, because the announcement will put your brand name in the same answer.

## Write it down

Every creator I check gets a short memo: who they are, how long they've covered the subject, what the audience looks like, how they've disclosed past sponsorships, any claims or controversies, and a plain recommendation. Each finding links to its source, with an archived copy for anything that might be deleted. The memo is the record that shows your brand did its homework, and it makes the next renewal decision a ten-minute read.

## Put the protections in the contract
- Clear disclosure at the start of every sponsored post, in the post itself, on every platform. Name the wording you expect, such as "#ad" or "Paid partnership with."
- Your approval before anything goes live. The FTC's guidance recommends it, and it's the only practical way to catch ephemeral formats like Stories.
- The approved claims, in writing, and a line saying the creator makes no others.
- A statement that the creator hasn't bought followers, views, or engagement, and won't during the term, with termination if that turns out to be false.
- Your right to remove or require edits to sponsored posts, and a clean exit if a past controversy surfaces that the creator didn't disclose.

## How I handle this for clients

I run creator and spokesperson checks for brands, agencies, and communications teams before a contract is signed: archive review, audience reading, disclosure history, identity, and what search and AI assistants say, delivered as one sourced memo per person with a recommendation. The same skills sit behind my [reputation and perception work](https://gerriscorp.com/services/reputation/), and agencies that want a quiet second opinion can use my [agency partner arrangement](https://gerriscorp.com/services/agency-partner/). If there's a name on your shortlist, [send it to me](https://gerriscorp.com/contact/).

## Want me to handle this for you?

This guide shows you how to do it yourself. If you'd rather hand it to someone who does this work for clients, I'm glad to help: tell me what's happening and I'll tell you where I'd start.

[Book a 30 minute call](https://calendly.com/chrisabraham/30) [Call +1 202-352-5051](tel:+12023525051) [Email chris@gerriscorp.com](mailto:chris@gerriscorp.com)

If your company hires through Upwork, you'll find me [there as well](https://www.upwork.com/freelancers/chrisjabraham).

## References
- [FTC: Trade Regulation Rule on the Use of Consumer Reviews and Testimonials, 16 CFR Part 465 (Federal Register, August 22, 2024; effective October 21, 2024)](https://www.federalregister.gov/documents/2024/08/22/2024-18519/trade-regulation-rule-on-the-use-of-consumer-reviews-and-testimonials)
- [FTC: Federal Trade Commission announces final rule banning fake reviews and testimonials (August 14, 2024)](https://www.ftc.gov/news-events/news/press-releases/2024/08/federal-trade-commission-announces-final-rule-banning-fake-reviews-testimonials)
- [FTC: FTC's Endorsement Guides: What People Are Asking](https://www.ftc.gov/business-guidance/resources/ftcs-endorsement-guides)
- [eCFR: Guides Concerning the Use of Endorsements and Testimonials in Advertising, 16 CFR Part 255](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-B/part-255)

Written by [Chris Abraham](https://gerriscorp.com/about/), founder of Gerris Corp in Arlington, Virginia, from his own client engagements, with every technical claim checked against the documentation listed. Websites since 1994, digital marketing since 2002. [Editorial standards](https://gerriscorp.com/standards/) · [Upwork profile](https://www.upwork.com/freelancers/chrisjabraham)