Vet an influencer before you sign

Short answer: Vet an influencer on five things before you sign: whether their audience matches your buyer (checked with the platform’s own audience data), whether their engagement looks earned, whether their past sponsored posts were disclosed properly, whether their content and claims fit your brand and category, and whether they accept the contract terms you need on disclosure, approvals, usage and data. This matters for legal reasons as well as results: under the FTC’s Endorsement Guides, an advertiser can be liable for a deceptive endorsement even when the influencer is not, and advertisers are expected to guide and monitor the people they pay.

Who this guide is for

This guide is for brands about to pay an influencer or creator to post to their own audience on Instagram, TikTok or YouTube. It applies whether you find creators yourself, through a platform marketplace or through an agency. If you are only buying videos to run on your own accounts or as ads (often called UGC), the pricing and rights side is covered in what creator-led content costs; the vetting steps on content fit and disclosure still apply.

A disclosure: SGNL lists influencer sourcing and creator partnerships among its services. We have no published influencer campaign results, so this guide relies on FTC rules and the platforms’ own documentation. The Vaunt example in Step 2 describes a program that is one month old.

Step 1: Decide what you are buying

Write down which of three things you want, because each one is vetted differently, and vetting for the wrong goal means paying for reach when you needed content you can reuse, or the reverse:

• Reach: the creator posts to their audience, and you are paying for that audience’s attention.

• Content: the creator makes videos you will run yourself, often as ads.

• Both: the creator posts, and you also license the post to run as an ad.

If you want reach, audience fit is the most important check, because you are paying for who sees the post. If you want content, the creator’s on-camera ability and the usage rights matter more than their follower count, because you will supply the audience through your own ads. Both points are my judgment.

Step 2: Check audience fit with platform data

Follower counts say little about who the audience is, and paying for an audience in the wrong country or age group buys reach that cannot become customers. Ask for the audience breakdown from the platform itself, or use the platforms’ brand tools:

• TikTok One lets brands search creators and filter by audience country or region, age range and gender ratio, and by performance metrics such as median video views and engagement rate. TikTok recommends reviewing a creator’s follower growth, views and engagement over time, their audience demographics and their recent organic and sponsored videos (TikTok One help, last updated June 2026).

• Meta Creator Marketing Hub, available in Meta Business Suite and Ads Manager, helps brands discover and evaluate Instagram creators for branded content and partnership ads (Instagram Help Center). Access depends on eligibility, so it may not be available to every account.

If a creator is not on these tools, ask for a live screen share of their audience insights, or recent screenshots with the date visible. Check three things: the share of the audience in the countries where you sell, the age range against your buyer, and whether the audience matches the topic you need them to talk about.

Vaunt example: start from your own audience data

For our client Vaunt, a private aviation membership app, SGNL’s close-out report for August 28 to September 27, 2026 recorded Vaunt’s own Instagram audience as 65% men and 56% aged 25 to 44, with New York the largest city at 17% (SGNL, “Vaunt 30-Day Close-Out & Q4 Plan,” September 28, 2026). That is the benchmark to compare a creator’s platform audience data against.

Vaunt also started an influencer program. In its first month, to September 22, 2026, 17 creators signed up with about 305,000 followers combined (SGNL September draft report, single-source). We have no performance data from the program yet, and our files do not show whether those creators were checked against Vaunt’s audience in the way this step describes, so this is a program size, not a result.

Step 3: Check whether engagement looks earned

Bought followers and engagement raise the price you pay per real viewer, so check this before you agree a fee. Engagement rate is useful only if you know the formula. TikTok One calculates it as likes, comments and shares divided by video views (TikTok One reporting); other tools divide by followers or reach, which gives a different number for the same post. Ask for the formula along with the figure, and see what engagement rate measures for the other common metrics.

Then look past the averages. These are practical checks, not proof; none is conclusive on its own, and they follow TikTok’s own advice to review follower growth, views and engagement over time:

• Read the comments on the last ten posts. Specific questions and replies about the content are a good sign. Many generic comments (“Nice!”, emoji only) from accounts with no posts are a warning.

• Compare typical views with followers. A large following with consistently small view counts may mean the audience has gone quiet or was bought.

• Look at sponsored posts separately. If sponsored posts get far less engagement than organic ones, the audience may not respond to recommendations.

• Look for sudden follower jumps with no viral post to explain them.

The FTC’s Consumer Reviews and Testimonials Rule makes it illegal to buy or sell fake indicators of social media influence, such as bot followers or fake views, when the buyer or seller knew or should have known they were fake and they misrepresent influence for a commercial purpose (16 CFR §465.8). The FTC’s Q&A says a business is not liable under that provision just for hiring an influencer who happens to have fake followers (FTC Q&A).

Fake followers still mean you pay for an audience that does not exist.

Step 4: Check their disclosure history

Look at the creator’s last ten sponsored posts (my suggested sample, enough to see a pattern) and compare them with the FTC’s guidance for influencers (Disclosures 101, November 2019):

• The disclosure sits with the endorsement itself. The FTC says disclosures that appear only on a profile page, at the end of a video, or behind a “more” link are likely to be missed.

• In a video, the disclosure is in the video itself, ideally both said and shown on screen. A disclosure in the description alone does not meet the guidance.

• The language is clear (“ad,” “sponsored,” “Thanks to [Brand] for the free product”), and avoids terms such as “sp,” “spon” or “collab.”

• The disclosure is not mixed into a block of hashtags.

• The creator does not rely only on the platform’s paid-partnership label.

Advertisers share responsibility for disclosure. In November 2023, FTC staff sent warning letters to two trade associations and 12 dietitians and other health influencers about Instagram and TikTok posts that did not adequately disclose payment. The letters cited inconspicuous placement, ambiguous language and failure to identify the sponsor, and noted possible civil penalties of up to $50,120 per violation for future failures (FTC, November 15, 2023).

Step 5: Check content and claims fit

A creator’s past claims become your brand’s problem the day they post for you. Watch at least twenty recent posts, organic and sponsored (again my suggested sample), and ask:

• Would you be comfortable with your brand appearing next to these posts?

• Does the creator speak in a way your buyers trust?

• Have they promoted competitors recently, and do you need exclusivity?

• Have they made claims about products that would need proof?

The FTC’s guidance tells influencers they cannot talk about experience with a product they have not tried, cannot call a product terrific if they thought it was terrible, and cannot make claims that would require proof the advertiser does not have, such as scientific proof that a product treats a health condition (FTC, Disclosures 101). If you sell in health, finance or another regulated category, decide before signing which claims the creator may and may not make.

Step 6: Agree the contract terms

The FTC’s Endorsement Guides say advertisers should give endorsers guidance on avoiding misleading statements and disclosing material connections (any relationship that could affect how people weigh the endorsement, such as payment or free product), monitor their compliance, and act to fix problems (16 CFR §255.1(d)). Write that into the agreement, along with the commercial terms:

• Deliverables: number of posts, formats, platforms and posting dates.

• Disclosure: the exact disclosure wording and placement, spoken and on screen for video.

• Brief and approval: a written creative brief, what you approve before posting (claims, mandatory lines), and what stays the creator’s creative choice.

• Claims: the claims the creator may make and the ones they must not.

• Usage and paid amplification (paying to show the creator’s post to more people as an ad): whether and how long you can run the post as an ad, on which platforms, and with which in-platform permissions. Article 1 covers usage rights pricing.

• Exclusivity: which competitors, for how long, and the fee.

• Performance data: which metrics the creator shares (for example reach, views, link clicks), from which tool, and by when after posting.

• Corrections and takedowns: what happens if a post is non-compliant or inaccurate, and how fast it is fixed.

• Payment terms and what happens if a deliverable is missed.

A vetting scorecard

Score each shortlisted creator from 1 to 5 on each row, multiply by the weight and add up. The weights are a suggested starting point for a reach-focused partnership; adjust them to Step 1.

Red flags that should stop or pause a deal

• They refuse to share audience data from the platform.

• Sponsored posts in the past year have no disclosure, or only a hashtag at the end.

• They will not use your disclosure wording.

• They promise specific sales or results. Nobody controls how an audience responds, so a promise like this is a sign they are selling rather than assessing.

• Engagement comes mostly from accounts that look automated.

• They have made health or financial claims they could not support.

Tradeoffs and limitations

• Platform tools show what the platform measures. Audience data is estimated and differs between tools.

• Vetting takes time. For a single low-cost post, a shorter check of Steps 2, 4 and 5 may be enough.

• Smaller creators have less history. A creator with few sponsored posts cannot show a disclosure record; make the contract terms do more of the work.

• This is not legal advice. Have counsel review the agreement, especially for regulated products and minors.

• When another option fits better. If your buyer trusts your founder or your own experts more than outside creators, putting them on camera may do more than an influencer partnership. If you need a large creator programme with many partners, a specialist influencer agency or a platform marketplace may run it more efficiently than a generalist partner.

Where SGNL fits, and when it does not

SGNL offers influencer sourcing and creator partnerships, and our usual model puts the founder or expert on camera (how our own system works). We have no influencer campaign results to publish; the Vaunt program in Step 2 has no performance data yet. Whoever runs your programme, ask them to show you their vetting scorecard and their disclosure checks, and use the questions to ask before you hire.

Next step

Score your current shortlist with the table above, ask each creator for platform audience data, and send the nine contract terms to your lawyer before you agree a fee. If you want SGNL to source and vet creators, see SGNL’s Influencers & Creators service.

Sources

All accessed October 10, 2026.

• Federal Trade Commission, Guides Concerning the Use of Endorsements and Testimonials in Advertising, 16 CFR Part 255 (revised 2023). https://www.ecfr.gov/current/title-16/chapter-I/subchapter-B/part-255

• Federal Trade Commission, “Disclosures 101 for Social Media Influencers,” November 2019. https://www.ftc.gov/business-guidance/resources/disclosures-101-social-media-influencers

• Federal Trade Commission, “FTC Warns Two Trade Associations and a Dozen Influencers About Social Media Posts Promoting Consumption of Aspartame or Sugar,” November 15, 2023. https://www.ftc.gov/news-events/news/press-releases/2023/11/ftc-warns-two-trade-associations-dozen-influencers-about-social-media-posts-promoting-consumption

• Federal Trade Commission, Trade Regulation Rule on the Use of Consumer Reviews and Testimonials, 16 CFR Part 465, effective October 21, 2024. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-D/part-465

• Federal Trade Commission, “The Consumer Reviews and Testimonials Rule. Questions and Answers.” https://www.ftc.gov/business-guidance/resources/consumer-reviews-testimonials-rule-questions-answers

• TikTok Ads Manager Help, “How to find creators who work with TikTok One,” last updated June 2026. https://ads.tiktok.com/help/article/how-to-find-creators-in-tiktok-one

• TikTok Ads Manager Help, “About TikTok One Project Reporting,” last updated October 2025. https://ads.us.tiktok.com/help/article/about-tiktok-one-campaign-reporting?lang=en

• Instagram Help Center, “About Meta Creator Marketing Hub.” https://www.facebook.com/help/instagram/337707278243327/

• SGNL Media, “Vaunt - September 2026 Performance Report (Draft),” September 22, 2026, and “Vaunt 30-Day Close-Out & Q4 Plan,” September 28, 2026 (SGNL-authored; single-source figures). Not public.

About the author

Andrew Moullin is co-founder and Creative Director of SGNL Media, where he leads creative and strategy for a four-person team that builds media systems for founders, experts and brands. Before marketing, he played professional soccer for San Antonio FC and Atlanta United 2, then coached.