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Lesson 1 of 7 · 6 min read

UGC is a format, not a customer

What a UGC ad is, and where the honesty line sits: a creator who presents and demonstrates versus a customer who testifies.

A moment at work · fictional example

Jo has watched dozens of ads where someone holds a phone at arm’s length and talks about a product. Some of those speakers are customers. Some are paid presenters. Before Fernway makes one, Jo needs to decide which kind its speaker will be.

You will make: Write the honesty line for your own ad. Follow the fictional example first, then try it with material you are permitted to use.

UGC is a look, not a speaker

UGC stands for user-generated content. In advertising, the term now names a look: one person, a phone camera at arm’s length, talking straight to the viewer. It looks like a post a person made, not an ad a company made.

The look does not make the speaker a customer. A UGC ad can feature a real customer, a paid creator, an actor or an AI-generated creator. Each one may say different things.

In this course you make one UGC ad for one product. Your output from this lesson is the honesty line. It is a short list of what your creator may say, and what only a real customer could say.

Present or testify

The FTC separates two kinds of speech in an ad. A presenter describes a product, demonstrates it and explains it. A testimonial reports the speaker’s own opinion or experience as someone who used the product.

The FTC’s Endorsement Guides, 16 CFR Part 255, give an example. An actor hosts an infomercial for a home fitness machine and says it is the most effective one they have ever tried. The Guides call that an endorsement, even from a script, because viewers believe it reflects the actor’s own views.

In a second version, the actor describes how the machine was designed, demonstrates it, and gives the price. The actor says nothing that sounds like a personal view. The Guides say that version contains no endorsement.

Part 255 also says an endorsement must reflect the honest opinions, findings, beliefs or experience of the endorser. When an ad says the endorser uses the product, the endorser must have been a bona fide user of it.

The rule on fake testimonials

The FTC’s Rule on the Use of Consumer Reviews and Testimonials is 16 CFR Part 465. It was published on August 22, 2024, and took effect 60 days later, on October 21, 2024.

Section 465.2 makes it a violation for a business to write or create a consumer testimonial that misrepresents three things. They are that the person giving it exists, that they used the product, and what their experience was.

The FTC’s announcement of the rule names AI-generated fake reviews as one target. An AI-generated creator does not exist, so she cannot give a consumer testimonial. A line like “I use it every week” misrepresents all three things.

So an AI creator may present, demonstrate and explain. She never claims she used the product, and she never reports a result such as money saved.

Real creator or AI creator

A real creator can testify if the words are true. They must have used the product, and the words must be their honest experience. Get a signed release for their face and voice before you film.

An AI creator costs less and needs no casting call. In exchange, she can only present. Design her from a written description, not from a photo of a real person.

To clone or edit a real person’s face or voice, get written consent first. Lesson 6 of Emeri’s course Training videos with AI covers the state laws and a consent checklist. This course does not repeat it.

Label it where people watch

TikTok’s Community Guidelines require creators to label AI-generated or significantly edited content that shows realistic-looking scenes or people. TikTok may remove, restrict or label content that is not labeled.

YouTube requires creators to disclose AI-generated or altered content that seems realistic. Its help page lists a realistic scene that did not occur as one case. Creators set the AI use attribute in YouTube Studio when they upload.

A realistic AI creator fits both descriptions, so turn the label on. Add a line in the frame as well, such as “AI-generated creator”, for the first seconds. The platform label stays on the platform, and the line in the frame goes wherever the file goes.

This lesson summarizes rule texts and help pages read on October 28, 2026. It is not legal advice. Ask a lawyer about your own ads.

Worked example · Fernway

Jo draws the honesty line for Fernway’s ad

Fernway is a fictional 14-person company with a meal-planning app. Its free pantry check is a two-minute quiz in the app that ends with a waste score and a list of what to use first. Jo Okafor, Fernway’s growth lead, needs a 55-second vertical ad for TikTok and Instagram Reels. Jo has no studio, no casting budget and a $25 cap for generation.

  1. Jo lists the speakers Fernway could use. A real customer could testify, but none has offered to appear on camera. A paid creator needs a fee and a release. Neither fits a $25 cap.
  2. Jo chooses an AI-generated creator and names her Maya. Fernway designs Maya from a written description, not from any real person. Her voice will be a stock text-to-speech voice from a library, not a clone.
    What would you do next?Jo’s first idea for the hook is Maya saying, “I used to throw out half my groceries.” Can Maya say it?Think it through, then show the answer

    No. Maya does not exist and has never bought groceries. The line reports an experience she never had, which Section 465.2 forbids in a testimonial. Lesson 2 replaces it with a fact that has a source.

  3. Jo writes the honesty line. Maya presents the pantry check, demonstrates it on screen and explains what it does. She never says she used it, and she never reports a result such as money saved.That answers the question you guessed at: Guess: in an ad, can an AI-generated creator say that she has used the product?
  4. Jo checks the line against the infomercial example in Part 255. An actor who demonstrates and describes, without giving a personal view, is not endorsing. Maya follows the same pattern.
  5. Jo plans the disclosure. The AI label goes on in each app at upload. The words “AI-generated creator” sit in the frame for the first seconds.
    What would you do next?The platform label is already on. Why add the line in the frame?Think it through, then show the answer

    The platform label stays in the app where Jo set it. The line in the frame travels with the file. It is still there if someone downloads the video or posts it somewhere else.

  6. Jo adds a rule for the product screens. The pantry check in the ad runs on test data, so its result carries the label “Demo result”. Fernway never shows a screen the app does not have.

Jo has the honesty line at the top of the ad plan. Maya may present, demonstrate and explain. She may not claim use, report a result or speak as a customer. The AI label and the line in the frame go on every version. Lesson 2 writes the script inside that line.

Go deeper: the research and edge cases

Optional. The exercise needs only what is above.

More from the rule texts

Part 465 defines a consumer testimonial as an advertising message that consumers are likely to believe reflects the opinions, beliefs or experiences of a consumer who used the product. The definition includes demonstrations and depictions of a likeness, not only words.

Part 255 has a rule for ads that present people as actual consumers. Such ads should use actual consumers, or clearly and conspicuously disclose that the people shown are not actual consumers.

The FTC announced the revised Endorsement Guides on June 29, 2023. The announcement says the new definition of endorsement clarifies how far it covers fake reviews, virtual influencers and tags in social media.

More from the platforms

In May 2024, TikTok announced that it reads C2PA Content Credentials to label AI content made on some other platforms. A label can then appear even when the creator forgets it. Do not rely on that.

YouTube’s help page says creators who repeatedly do not disclose may face penalties. It lists removal of content and suspension from the YouTube Partner Program among them.

Instagram’s help center has a page on labeling AI content in its mobile app. Read it before you post a Reel.

Starter prompts

  • Sort my lines: present or testify

    Here is the script for a short creator-style video ad: [paste the script]. The speaker is [an AI-generated creator / a paid actor / a real customer who has used the product]. Sort every line into one of three groups: presents or explains the product; demonstrates it on screen; or states the speaker’s own opinion, use or result. For each line in the third group, say whether this speaker can truthfully say it. If not, suggest a rewrite that presents or demonstrates instead. Do not add any claim, number or result that is not in my script.

  • Choose a real or an AI creator

    I am planning a short creator-style video ad for [product]. Interview me, one question at a time, to decide between a real customer, a paid creator and an AI-generated creator. Ask whether a real customer will appear and speak truthfully about their own use, what budget I have for a fee and a release, and whether any line in my plan depends on personal experience. Then recommend one option in two sentences. Remind me that an AI-generated creator may present and demonstrate, but may never claim to have used the product. Do not give legal advice.

  • Write the disclosure line

    Write three versions of an on-screen disclosure for a vertical video ad whose creator is AI-generated. Each version must be four words or fewer and readable in under two seconds. Then say where the line should sit in the first three seconds so it does not cover the creator’s face or the captions. Use plain words. Do not use brand names or the phrase "virtual influencer".

When not to use AI

  • An ad where real experience is the point, such as a customer’s own story. Use the real customer, with a signed release, and keep their words true.
  • Deciding whether your ad complies with the law. An assistant can sort your lines, but a lawyer answers that question.
  • Building a creator from a real person’s photo or voice without written consent. See the consent lesson in Training videos with AI first.
Recall from memoryWhat may an AI-generated creator do in an ad, and what may she never do?Answer it without looking back, then show the answer

She may present the product, demonstrate it on screen and explain it. She may never claim she used it or report a result, because she does not exist and cannot give a testimonial.

Exercise · your project

Write the honesty line for your own ad.

  1. Pick one product and the one free action you want viewers to take.
  2. Decide on a real creator or an AI creator, and write the reason in one sentence.
  3. Write two lists: what your creator may say, and what only a real customer could say.
  4. Write your disclosure line, and note where each platform’s AI label is set.
  5. Put the honesty line at the top of your ad plan. Every later lesson adds to this plan.

Your project workspace

Leave with work you can use.

Write here or use an approved tool. Use fictional or permitted information. Your work stays in this open page and disappears on reload. Nothing is submitted to Emeri or an AI service.

This is self-review. Completion is saved on this device and does not award certification.

Sources