What are the rules for a referral or affiliate programme?
Three sets of rules apply: disclosure, email and the app stores. The FTC's Endorsement Guides say a connection the audience would not expect, such as a commission, must be disclosed clearly and conspicuously. In the UK, CAP's advice on the ASA's site holds both the business and the affiliate responsible, and the Information Commissioner's Office says encouraging customers to forward your marketing by email or text is likely to make you its instigator, so you need the friend's consent. Apple and Google Play rule out incentivised ratings and reviews. Since 21 October 2024 an FTC rule has barred incentives tied to a review's sentiment. This page is not legal advice.
What the regulators and the stores say, in their own words
This page covers the United States and the United Kingdom only.
When there exists a connection between the endorser and the seller of the advertised product that might materially affect the weight or credibility of the endorsement, and that connection is not reasonably expected by the audience, such connection must be disclosed clearly and conspicuously.
Because knowledge of this compensation could affect the weight or credibility site visitors give to the blogger's reviews, the reviews should clearly and conspicuously disclose the compensation.
Both the business and the affiliate marketer are responsible under the Code, notwithstanding the fact that the ads may have been created solely by the affiliate without any input from the business themselves.
Asking people to send your electronic mail marketing to friends or family is often called 'refer a friend', 'tell a friend' or 'viral marketing'. If you encourage people to do this, you're likely to be instigating those messages and you must comply with PECR. You don't need to give an incentive for it to count as instigating. It's enough that you actively encourage someone to pass on your message.
You must obtain valid consent. This is unlikely to be possible in practice because you have no way to show they agreed to receive your marketing.
Developers must not attempt to manipulate the placement of any apps on Google Play. This includes, but is not limited to, inflating product ratings, reviews, or install counts by illegitimate means, such as fraudulent or incentivized reviews and ratings, or incentivizing users to install other apps as the app's main functionality.
What that means if you have just launched
- You may pay commission. The affiliate must say so. The FTC's questions and answers suggest wording such as "I get commissions for purchases made through links in this post", and say the closer the disclosure is to the recommendation, the better.
- In the UK, label it as an ad, at the start. CAP's advice suggests an identifier such as "Ad" at the beginning of a post. It says a disclaimer at the bottom is unlikely to be sufficient, and that a line saying the author "may" receive a commission is unlikely to be acceptable.
- Tell affiliates what to say, then check. The Guides say advertisers should give endorsers guidance, monitor their compliance and act on what they find. Google Play's App Promotion policy makes the developer responsible for whether affiliates associated with an app comply.
- A rewarded customer who posts in public discloses the reward. The FTC's answers say a disclosure is appropriate when someone shares a product because they are compensated, for example with a discount on a future purchase.
- Show the code. Do not write the email. In the ICO's guidance, a scheme that shows each customer a unique code and leaves it to them whether and how to share it is not instigating. A retailer that creates a marketing email for customers to send is. The ICO's Guide to PECR, which says it is under review, advises against asking customers for their friends' contact details.
- An affiliate who emails for you does not take the rule off you. The ICO's guidance says that when you ask another organisation to send your marketing you may still be responsible as the instigator, and both parties must comply. Cold email and DMs has the consent rules.
- Never reward a rating or a review in a store. Apple's guidelines say paid or incentivised feedback may get you expelled from the Apple Developer Program, that an app must not force users to rate or review it in order to use it, and that review prompts must use Apple's own API. Google Play lists asking for a rating while offering an incentive as a common violation.
- Outside the stores, never tie a reward to a good review. The FTC's answers on its review rule allow an incentive for a review only when nothing, said or implied, requires a particular sentiment. They add that failing to disclose the incentive could still break the FTC Act.
None of the store pages read here mentions a reward for inviting a friend, though guideline 5.6.3 of Apple's guidelines rules out manipulating referrals to an app. The other store rules are on App Store and Google Play, and creators paid a fee are on Influencers and paid posts.
The numbers
None of the pages read here sets a commission rate or the size of a reward. The figures they give:
- 21 October 2024. The day the FTC's rule on consumer reviews went into effect. It lets courts impose civil penalties for knowing violations.
- Three times in 365 days. How often Apple's ratings page says an app may prompt for a rating.
What the tracking software costs
Three tools that track affiliate sales publish prices, read on 8 October 2026. Each shows a 14 day free trial.
- Rewardful starts at $49 per month, for up to $7,500 a month in revenue attributed to affiliates, with a 0% transaction fee. Its prices are in USD and taxes are additional.
- FirstPromoter shows a Starter plan at $49 a month, for up to $5,000 a month in revenue from affiliates.
- Tolt shows a Basic plan at $69 a month, for up to $10,000 a month earned from affiliates.
The commission or reward comes on top. Count both in your customer acquisition cost and set that against lifetime value. A reward larger than what a customer pays you loses money on every referral.
How Sami uses it
Sami ranks referrals and affiliates against the other channels for your product and says why they are in or out. The plan puts free methods before paid ones.
AskSami never posts anywhere for you, never spends your money and never writes to your code. You do those things yourself. Recruiting affiliates, writing their terms and paying them stay with you. The numbers you bring back, such as referred signups and commission paid, become dated records. Signups and payments are tied to their source where the snippet in your product recorded one.
Questions people ask
Do I have to disclose affiliate links?
Yes, where the reader would not expect the payment. The FTC's Endorsement Guides say a blogger paid through affiliate links should clearly and conspicuously disclose the compensation. In the UK, CAP's advice says rule 2.1 of the CAP Code requires marketing to be obviously identifiable as such.
Is writing "affiliate link" enough?
Not on its own in the US. The FTC's answers say consumers might not understand that it means the person is paid for purchases made through the link. They say "paid link" right next to the link should be adequate.
Am I responsible for what my affiliates say?
Yes. CAP's advice says both the business and the affiliate are responsible under the Code, even when the affiliate made the ad alone. The FTC's Guides say an advertiser may be liable for a deceptive endorsement even when the endorser is not.
Can I ask customers to email their friends about my product?
In the UK, only with the friend's consent. The ICO says encouraging customers to send your marketing is likely to make you the instigator, with or without a reward, and that valid consent is unlikely to be possible in practice. Its example of a scheme that complies shows each customer a code and does not suggest emails or texts.
Can I give users a reward for a 5 star review?
No. The FTC's answers on its review rule say paying incentives for 5 star reviews breaks the rule even if reviewers disclose the incentive. Apple and Google Play rule out incentivised reviews.
Read next
- What are the rules for paying an influencer to post about my product?
- Is it legal to cold email or DM people about my product?
- How do I get my app approved and found on the App Store and Google Play?
- What is customer acquisition cost, and how do I work out mine?
- What is customer lifetime value, and how do I work out mine?
- Which distribution channel should I use for a product I just launched?
- What is retention, and how do I read mine?
- What is churn, and how do I work out my churn rate?
AskSami reads what you give it, all of it optional: your GitHub repository, up to 40 pages of your live site, and the screenshots, ad exports and payment exports. From that it writes an honest read of why the product does or does not sell, and a ranked plan of up to ten ways to get customers, free methods before paid ones.
Sources
- Federal Trade Commission, in the Electronic Code of Federal Regulations, Guides Concerning Use of Endorsements and Testimonials in Advertising, 16 CFR Part 255, published 26 July 2023, shown up to date as of 6 October 2026. Read on 8 October 2026.
- ASA and CAP, Online Affiliate Marketing, advice from the CAP Executive, 22 March 2023. Read on 8 October 2026.
- Information Commissioner's Office, Guidance on direct marketing using electronic mail: How do we comply with the PECR electronic mail marketing rules?. Read on 8 October 2026.
- Apple, App Review Guidelines, last updated 8 June 2026. Read on 8 October 2026.
- Google Play Console Help, User Ratings, Reviews, and Installs. Read on 8 October 2026.
- Federal Trade Commission, The Consumer Reviews and Testimonials Rule: Questions and Answers, November 2024. Read on 8 October 2026.
- Federal Trade Commission, FTC's Endorsement Guides: What People Are Asking, June 2023. Read on 8 October 2026.
- Google Play Console Help, App Promotion. Read on 8 October 2026.
- Information Commissioner's Office, Guide to PECR: Electronic mail marketing. Read on 8 October 2026.
- Apple, Ratings, reviews, and responses. Read on 8 October 2026.
- Rewardful, Pricing. Read on 8 October 2026.
- FirstPromoter, Pricing. Read on 8 October 2026.
- Tolt, Pricing. Read on 8 October 2026.
Checked on 17 October 2026. Every rule, price and figure on this page was read on the page it links to, on the day shown beside it above. They change, so open the source before you rely on one.