OVO field guide
Where do I find UGC creators?
You are hiring a production skill, not an audience
The asset is a video file you license and run from your own account, so a creator's follower count buys you nothing unless you also plan to publish from their handle. A standard in-feed ad from your brand account uses the footage and never touches the creator's profile. Spark Ads work the other way. TikTok's documentation states that with Spark Ads, all views, comments, shares, likes, and follows gained from boosting the video during the promotion are attributed to your organic posts, so when the underlying post sits on a creator's account, your media spend grows that account. Decide which of the two you are buying before you shortlist anybody, because the second one is an audience purchase wearing a production brief.
Follower count is also the most gameable number on a profile. The Federal Trade Commission's rule on consumer reviews and testimonials, effective October 21, 2024, makes it a violation to purchase or procure fake indicators of social media influence that the buyer knew or should have known were fake. The rule defines those indicators to include followers, subscribers, views, likes, shares and comments. A number you can buy is a weak filter for a job that never needed it.
Your own customers and reviewers
Start with people who have already bought. A customer filming themselves using the product passes the endorsement test by construction: the Federal Trade Commission's Endorsement Guides state that when an advertisement represents that the endorser uses the endorsed product, the endorser must have been a bona fide user of it at the time the endorsement was given. Your reviews inbox, your support tickets and your tagged mentions are full of people who cannot fail that test.
What you give up is speed and consistency. Volume is unpredictable, and most customers have never lit a shot or recorded clean audio. Three traps sit on this route, all of them cheap to avoid.
- Telling a customer they might be featured is itself a material connection. The Endorsement Guides count the possibility of being paid, of winning a prize, or of appearing on television or in other media promotions as connections that need disclosing, and the Federal Trade Commission's own suggested wording is that customers were told in advance they might be featured in an ad.
- Paying for a positive review is a separate violation. The 2024 rule bars providing compensation or other incentives in exchange for, or conditioned on, consumer reviews expressing a particular sentiment. Pay for the work, never for the verdict.
- A public post is not yours to run. TikTok's United States terms list using another user's content for commercial purposes among the things you must not do on the platform, unless that user permits it. Being tagged is not a license. Get one in writing.
Creator marketplaces
Marketplaces solve the volume problem. You post a brief, filter by niche and format, and see applicants inside a day. TikTok's own creator marketplace, now reached inside TikTok One, is the platform-native option, and the independent marketplaces hold searchable pools of creators who list UGC as a service.
The weakness comes from the same mechanism as the speed. Applicants have usually never touched your product, which runs straight into the bona fide user requirement above. The 2024 rule sharpens that risk. Section 465.2(b) puts the violation on the business that disseminates a testimonial it knew or should have known was false about the person's use, not only on the creator who filmed it. The fix is to ship the product first and let the calendar absorb the days it takes to arrive and get used.
Portfolios are also self-reported, so a reel can contain work the applicant did not shoot. Output converges too. Creators working the same briefs for the same categories every week produce videos that look like everyone else's, which defeats the point of the format.
An open call to your own list
An open call to your customer list is the cleanest of the four under the 2024 rule, and the carve-out that makes it clean is narrower than it first looks. Section 465.2(d) states that paragraphs (b) and (c) of that section do not apply to reviews or testimonials that resulted from a business making generalized solicitations to purchasers to post reviews or testimonials about their experiences. Those are the paragraphs on purchasing a review and on putting out a testimonial that misstates the person's experience with the product. A broad ask sent to everybody who bought in a given window qualifies. A targeted ask aimed only at the customers who left five stars does not.
The carve-out never reaches two things. Writing or creating a testimonial that materially misrepresents that the person used the product stays a violation under 465.2(a), and paying for a particular sentiment in a review stays a violation under 465.4, however the ask was worded.
In practice this is one email. Send it to every purchaser from a defined window, ask for a video about their honest experience, and say plainly that selected videos may run in advertising. Make clear that anything you pay is for their time, not for what they say. Craft variance is the widest of any route here, so plan to use a small fraction of what arrives and set aside time to watch it all.
A creator marketing company
A creator marketing company sits between you and the creators and takes over casting, briefing, rights paperwork, revisions, and replacing anyone who misses the spec. What decides whether that fits is how many formats you are running at once, whether anyone internally owns the licensing and disclosure paperwork, and how fast you need a replacement when a creator goes quiet.
One limit applies to every outside partner, including this one. Federal Trade Commission guidance says that delegating part of your promotional program to an outside company does not relieve you of responsibility under the FTC Act. Approval of the final creative, and the truth of what it claims, stays with the brand.
How to read a UGC portfolio in ten minutes
Watch three of a creator's videos with headphones on. The defects that cost the most are the ones you hear before you see them.
| What to check | What it predicts | How to test it |
|---|---|---|
| Audio floor | Room tone, clipping and plosives are the hardest defects to fix after the shoot | Listen at low volume. Hiss, echo, or a noise floor that jumps between cuts means no treated space and no external mic. |
| Lighting inside one take | Whether they control a space or shoot wherever they happen to be | Watch for exposure shifting mid-sentence and color changing between two shots of the same scene. |
| Hook delivery | Whether the opening frames identify the product before a viewer decides to keep watching | Mute the video. If the frame and the on-screen text alone do not tell you what the product is, the hook is being carried by the voiceover. |
| Spec compliance | Whether they can follow a brief instead of making what they prefer | Ask for a named aspect ratio, a length, and one spoken line. Compare what arrives against what you asked for, item by item. |
| Disclosure hygiene | A creator who cannot land a legible disclosure creates a compliance problem for you | Look at their past paid work. The Federal Trade Commission says a disclosure in a video belongs in the video rather than only in the description, and notes that some viewers watch without sound. |
Follower count is deliberately absent from this table. It predicts nothing about any of the five rows.
Run a paid test before you commit to anyone
One thing a portfolio cannot show you is revision behavior, because a portfolio only contains accepted work. Send the same brief to a small batch and pay for the test. Free work attracts the creators with the least demand for their time, and it tells you nothing about how somebody behaves once money is involved.
The test is not really measuring whether the video is good. It is measuring whether the deliverable matched the spec without a reminder, how long the second round took, and whether the pushback you got was useful. A creator who delivers the fourth-best video and hits every spec on the first pass will beat the one who delivers the best video three days late, once you are running a dozen assets a month.
Approve before, not after. Federal Trade Commission guidance on monitoring endorsers says there is no one-size-fits-all standard, and that if regular monitoring is too much for you, you should probably switch to pre-approval of posts. The same guidance notes it is much easier to review posts before they are posted than to search for them afterwards.
Settle these five things before anyone films
The bona fide user duty runs for as long as the ad runs. The Endorsement Guides state that the advertiser may continue to run the advertisement only so long as it has good reason to believe that the endorser remains a bona fide user of the product. A twelve-month usage term therefore carries a twelve-month diligence duty, and a creator who has switched to a competitor is a problem for an ad you are still running.
Usage, term, channels and exclusivity get named per asset, in writing, before production. Paid media, organic posting, your website, email and retail screens each need listing if you intend to use them, because a license that names none of them gets read narrowly later.
Whitelisting and Spark Ads are revocable in a way a delivered file is not. TikTok's documentation notes that a Spark Ad authorization has to be withdrawn before the video can be deleted from the organic account. An asset you host and run from your own account survives a falling-out. An authorization on somebody else's post does not.
Disclosure is decided by who paid and where it runs, not by the format. YouTube's policy states that creators and brands are responsible for understanding and fully following legal obligations to disclose paid promotion in their content according to their jurisdiction. At the paid promotion checkbox in YouTube Studio it adds that you may have more obligations depending on the laws in your jurisdiction, and that YouTube may act against content or accounts that do not follow them. TikTok's Branded Content Policy, effective August 31, 2026, requires a creator to enable the commercial content disclosure toggle when posting branded content, and requires that the product or service being promoted is sufficiently clear without a viewer having to open a profile page or a link.
If you cast a performer rather than a customer, say so. The Endorsement Guides work through a hidden-camera cafeteria ad where the net impression is that the speakers are actual customers, and conclude that if actors have been employed, this fact should be clearly and conspicuously disclosed. Federal Trade Commission guidance adds that statements like results not typical or individual results may vary will not change how a specific-results testimonial is read.
When the audience is actually the point
Everything above assumes the content runs on your channels and the creator's audience is incidental. When the audience is what you want, you are buying influencer marketing, and the screening inverts: growth curve, comment substance, overlap with your actual buyer, and past disclosure hygiene start mattering more than lighting. The pool of people who can shoot a clean product demo is much larger than the pool who can also bring a relevant audience. The companion page on finding influencers for your brand covers that path.
Frequently asked questions
Do UGC creators need followers?
No, when the content runs as an ad from your own brand account. You are licensing a video file, and the creator's audience is never involved in its distribution. Follower count starts mattering only if you also publish from the creator's handle, which is a different purchase. TikTok's documentation notes that engagement gained while boosting a Spark Ad is attributed to the original organic post, so that format does touch the creator's account.
Can I run a customer's TikTok video as an ad because they tagged my brand?
No. A tag is not a license. Under TikTok's United States terms, commercial use of another user's content is a prohibited use of the platform unless that user permits it, so a mention grants your brand no rights at all. Ask for a written license naming the channels and the term. If you gave the customer anything, including the prospect of being featured, that connection needs disclosing under the Federal Trade Commission's Endorsement Guides.
Does a UGC ad need a disclosure if it runs from my brand account?
The paid nature of a video in a paid placement is generally apparent, so the live question is whether the person on camera reads as an independent customer when they are not. The Endorsement Guides treat that as the thing to disclose. Their worked example covers an ad implying the speakers are real patrons, and concludes that where actors have been employed, the fact should be clearly and conspicuously disclosed. Advertisers are separately liable for misleading or unsubstantiated statements made through endorsements, whether or not the endorser is.
What if the creator has never used my product?
Ship it, and set the shoot date after delivery plus real use rather than after delivery alone. The Endorsement Guides require that an endorser presented as a user was a bona fide user when the endorsement was given. The 2024 rule adds a second exposure: disseminating a testimonial the business knew or should have known misrepresented the person's use is itself a violation. A creator reading a script about a product they never opened puts you on the wrong side of both.
Is a UGC video a review under the fake review rule?
It is a testimonial rather than a review, and the distinction is in the rule's own definitions. A consumer review is an evaluation published to a website or platform dedicated in whole or in part to receiving and displaying such evaluations. A consumer testimonial is an advertising or promotional message, including demonstrations, that consumers are likely to believe reflects the experience of somebody who used the product. A creator video running in your ads is the second one, so the testimonial provisions apply and the review-platform provisions mostly do not.
How many creators should I test before committing?
Enough to see the variance. For a new category that usually means a first batch of about five. Send every one of them the identical brief, because that is what makes the results comparable. Score each on whether the first pass met the spec without a reminder. That first-pass rate predicts how much of your next batch will be usable better than any single video does.
Where do I find UGC creators for a technical or unglamorous product?
Your customer base first, because product understanding is harder to teach than framing. Sales calls, onboarding sessions and support threads surface the customers who can already explain the product in plain language, and that explanation is most of the asset. Marketplaces work here too, though filters return fewer people, so plan on a longer brief and one extra revision round while the creator learns what the product actually does.
Should I use the same creators repeatedly or keep rotating?
Both, for different reasons. Repeat creators lower briefing overhead, deliver to spec more reliably, and keep using the product, which supports the ongoing bona fide user requirement that runs for as long as the ad runs. Rotate when your ad account shows the creative fatiguing rather than on a fixed schedule, and keep at least one new face in every batch so you always have a comparison against the people you already trust.
- eCFR: 16 CFR Part 255, FTC Guides Concerning the Use of Endorsements and Testimonials in Advertising (2023)
- Federal Trade Commission: FTC's Endorsement Guides, What People Are Asking (2023)
- eCFR: 16 CFR Part 465, Rule on the Use of Consumer Reviews and Testimonials (2024)
- Federal Register: Trade Regulation Rule on the Use of Consumer Reviews and Testimonials, effective October 21, 2024 (2024)
- Federal Trade Commission: Disclosures 101 for Social Media Influencers (2019)
- TikTok Ads: About Spark Ads (2026)
- TikTok: Branded Content Policy, effective August 31, 2026 (2026)
- TikTok: Terms of Service, United States (2026)
- YouTube Help: Add paid product placements, sponsorships and endorsements (2026)
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