Yes. FTC guidelines focus on the "material connection" between a creator and a brand, not the transfer of funds. If you use an affiliate link, you operate under a commercial agreement. Not reaching a payout threshold doesn't change the nature of the relationship.
Disclosures inform readers that a recommendation might be influenced by a potential incentive. Whether that incentive has turned into cash is irrelevant to the consumer's right to know. If the link tracks clicks for attribution, the intent to earn is legally present.
This applies to free products too. Receiving a "gift" for a review is a material connection. You must disclose that the item was provided by the brand, even if no money changes hands. It is safer to disclose by default than to wait for your first sale.
Treat every tracking link as an endorsement. Clear labeling ensures compliance regardless of your current account balance. ⚖️
Disclosure Desk
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Do you need a disclosure if your affiliate links haven't earned a cent yet?
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