What is UGC? User-generated content, explained
What counts as UGC, what “UGC creators” actually make, and the rules when a brand pays or reposts.
First brand read free. No filming.
On this page
The short answer
UGC (user-generated content) is content made by the people who use a product or website rather than by the brand itself: Reviews, photos, videos and posts by customers. Paid “UGC creator” videos copy that native style but are advertising, so they must be disclosed as such, and a brand needs permission before reposting a customer’s content.
Updated

Use UGC the right way
- 01
Ask before you repost
Message the customer, ask to use the video, and keep their yes in writing. To run it as an ad, use the platform’s own authorisation: a Spark Ads code on TikTok, a partnership ad code on Instagram.
- 02
Label anything you paid for
Turn on TikTok’s commercial content disclosure, Instagram’s Paid partnership label or YouTube’s paid promotion box, and say it in the video too: the FTC says a platform tool alone may not be enough.
- 03
Never invent a customer
No AI-generated “customer” testimonials and no reviews from staff passed off as independent. Present yourself as yourself.
- 04
Keep the native style
What makes UGC work is that it looks like a post, not an ad: phone framing, one person talking, a real reason to watch in the first seconds.
- 05
Measure by buyers
Compare UGC ads and posts by signups and sales, not by views alone.
UGC in six facts
Made by users, not the brand
Oxford: material “contributed by the people who use the website”. The OECD adds that it is published, takes some creative effort and is made “outside of professional routines”.
Paid “UGC” is an ad
When a brand pays for a review-style video or sends free product, the FTC treats it as an endorsement, and the connection “must be disclosed clearly and conspicuously”.
Free product counts as payment
The FTC, the UK ASA and the European Commission all say content made in exchange for gifted products must be labelled as advertising.
Reposting needs permission
A customer’s video is under copyright the moment it is made. Instagram puts the duty to get permission on whoever reposts, and crediting the creator does not make it original.
Fake testimonials are illegal
Since 21 October 2024 the FTC rule bans reviews and testimonials by people who do not exist, “such as AI-generated fake reviews”, or who never used the product.
Ads need the creator’s yes
TikTok Spark Ads and Meta partnership ads run creators’ posts as ads only with the creator’s authorisation.
The sources
Regulators’ and platforms’ own pages only, read on 2 October 2026. This is general information, not legal advice. Percify is not affiliated with any of them.
- What it says
- There is “no universally accepted definition”; proposes three criteria: published, creative effort, outside professional routines
- Applies to
- The definition of user-created content
- Date
- 2007
US FTC: Endorsement Guides
16 CFR Part 255, revised 2023, and the Disclosures 101 guide for influencers.
Source: law.cornell.edu; quote: Disclosures 101, read Invalid Date
- What it says
- Material connections, including free or discounted products, “must be disclosed clearly and conspicuously”
- Applies to
- Paid and gifted creator content, reviews, virtual influencers
- Date
- Revised 26 July 2023
US FTC: fake reviews rule
16 CFR Part 465, the rule on consumer reviews and testimonials.
- What it says
- Bans reviews by people who do not exist, “such as AI-generated fake reviews”, or who had no experience of the product
- Applies to
- Reviews and testimonials, including insiders’
- Date
- In force 21 October 2024
UK ASA / CAP
Recognising ads: social media and influencer marketing.
Source: asa.org.uk, read Invalid Date
- What it says
- Expects “a prominent ‘ad’ label upfront”
- Applies to
- Everything “from a post about a gifted product all the way through to a brand collaboration”
- Date
- Updated 6 August 2026
TikTok
Branded Content Policy and the Spark Ads help article.
Source: tiktok.com; quote: Spark Ads, read Invalid Date
- What it says
- Branded content “you must enable the commercial content disclosure toggle”
- Applies to
- Paid or gifted content; Spark Ads use creators’ posts “with their authorization”
- Date
- Effective 31 August 2026
Instagram
About original content, and the branded content and partnership ads help pages.
Source: help.instagram.com; quote: Partnership ads, read Invalid Date
- What it says
- Reposters are “responsible for obtaining any necessary permissions”; credit alone does not make a repost original
- Applies to
- Reposted content; paid branded content needs the Paid partnership label
- Date
- Help Center, read 2 October 2026
The kinds of UGC
Organic customer content
Reviews, unboxings, photos and videos customers post on their own. The original meaning of UGC; free, but you cannot order it and you need permission to reuse it.
Reviews and ratings
Written and star reviews on your site or marketplaces. Covered by the FTC’s 2024 rule: no fake, bought or insider reviews passed off as independent.
Paid “UGC creator” videos
A creator is paid or gifted product to make a natural, phone-shot video for the brand to post or run as an ad. Industry usage, not a legal category: legally it is an endorsement and must be disclosed.
Creator posts run as ads
A creator’s own post boosted by the brand through TikTok Spark Ads or Meta partnership ads, with the creator’s authorisation and a paid-partnership label.
Your own face, in the same native style
Not UGC, and it does not pretend to be: the founder or team talks to camera like a creator would. Percify makes these daily with your own face and voice from your site, labelled as AI where the platform asks, and posts the ones you approve.
Read next
Your questions, answered
Short answers to what people ask next.
User-generated content: content made by the people who use a product, platform or website rather than by the company behind it, such as customer reviews, photos and videos.
Someone paid, or sent free product, to make natural-looking, phone-style videos for a brand to post or run as ads. No regulator defines the term; legally their videos are endorsements and must be disclosed.
Organic UGC is made by customers on their own. Influencer and “UGC creator” content is made because a brand paid or gifted something, so it is advertising, whether it is posted on the creator’s account or the brand’s.
No. Their video is under copyright from the moment it is made, and Instagram puts the duty to get permission on whoever reposts. Ask, keep the yes in writing, and credit them.
Not as testimonials. The FTC’s 2024 rule bans reviews and testimonials by people who do not exist, including AI-generated ones. AI video of yourself, presented as yourself and labelled where the platform asks, is a different thing.
Percify is not UGC: it makes your own short videos in the same native, talk-to-camera style, presented with your own face and voice, and posts the ones you approve to your own accounts. Your first brand read is free.