Last Reviewed: September 2026

The AAMA Advertising Claims Checklist is designed to help advertisers, marketers, agencies, copywriters, strategists, researchers, creative teams, account professionals, brand managers, and reviewers identify advertising claims that require substantiation, qualification, disclosure, or additional professional review before publication.

Advertising claims are created by more than written copy. Headlines, images, demonstrations, testimonials, charts, product names, comparisons, pricing, disclosures, audio, editing, and context can all affect what an audience reasonably understands an advertisement to communicate.

The central review question is not simply whether each sentence is literally true. Reviewers should consider the complete impression created by the advertisement and determine whether every material express or implied claim can be supported.

This checklist focuses primarily on advertising practice in the United States. Particular industries may be subject to additional federal, state, regulatory, contractual, or professional requirements, so this resource should not be treated as legal advice.

1. Identify Every Express Claim

What does the advertisement directly say?

List every objective statement that can reasonably be tested or verified.

Examples may include:

• Saves 30%
• Works in five minutes
• Used by more than 10,000 businesses
• Lasts twice as long
• Reduces energy consumption
• Number one in customer satisfaction
• Made with recycled materials
• Improves conversion rate
• Clinically tested

Do not review only the headline.

Claims can appear in:

• Body copy
• Captions
• Buttons
• Footnotes
• Product names
• Charts
• Video narration
• Packaging
• Testimonials

Create a complete inventory before evaluating support.

2. Identify Implied Claims

What might a reasonable audience conclude even though the advertisement never states it directly?

An advertiser is responsible for reasonable implications created by the complete communication.

For example, showing a cleaning product removing a difficult stain in seconds may imply that ordinary customers can expect comparable performance under normal conditions.

Review:

• Images
• Demonstrations
• Before-and-after presentations
• Testimonials
• Headlines
• Product names
• Charts
• Editing
• Audio
• Comparisons
• Context

Ask:

What would someone reasonably believe after seeing this advertisement?

Do not limit review to what the advertiser intended to communicate.

3. Review the Net Impression

Does the advertisement as a whole create an accurate impression?

The Federal Trade Commission evaluates advertising based on the overall impression communicated to reasonable consumers, not isolated phrases considered independently.

Review the combination of:

• Copy
• Visuals
• Audio
• Layout
• Emphasis
• Demonstrations
• Disclosures
• Testimonials

An accurate sentence can still participate in a misleading advertisement when the overall presentation creates a different impression.

4. Separate Objective Claims From Opinion

Can the statement reasonably be measured or disproved?

Objective claims generally require an appropriate basis.

Examples include:

• 20% faster
• Lowest price
• More effective
• Lasts 12 hours
• Preferred by customers
• Reduces costs
• Improves performance

Subjective promotional language may function differently.

Examples might include:

• Our most exciting collection yet
• A beautiful way to start the day
• Our favorite design

Do not assume that adding enthusiasm automatically turns an objective assertion into subjective opinion.

5. Confirm Prior Substantiation

Did adequate support exist before the advertisement was released?

The FTC’s Advertising Substantiation Policy establishes the principle that advertisers should possess a reasonable basis for objective advertising claims before dissemination.

Do not:

• Publish first and search for evidence later
• Assume the claim is acceptable because nobody has challenged it
• Rely on evidence created after the campaign began as though it supported the original approval
• Assume competitors making similar claims proves the claim

Document the evidence used at the time of approval.

6. Match the Evidence to the Exact Claim

Does the research actually support what the advertisement says?

Having research is not enough.

Check whether the evidence supports:

• The specific product
• The specific benefit
• The advertised magnitude
• The relevant audience
• The stated duration
• The actual conditions of use

For example, research showing a 5% improvement should not support copy claiming a 30% improvement.

Research on one product version should not automatically support claims about another formulation, model, or service.

7. Evaluate the Quality of the Evidence

Is the evidence appropriate for the type of claim?

The strength of evidence required depends on the claim.

Potential evidence may include:

• Product testing
• Controlled experiments
• Scientific studies
• Sales records
• Customer records
• Independent research
• Survey research
• Technical specifications

Health and safety claims can require substantially stronger evidence than ordinary product claims. The FTC’s Health Products Compliance Guidance explains that health-related benefit and safety claims generally require competent and reliable scientific evidence.

Do not treat a customer anecdote as equivalent to controlled research when the claim requires scientific evidence.

8. Review Claims About Research

Does the advertisement accurately describe the evidence?

Statements such as:

• Studies show
• Research proves
• Clinically proven
• Scientifically demonstrated
• Doctors recommend

create claims about the evidence itself.

If an advertisement says “studies prove,” the advertiser should possess evidence that reasonably supports that level of representation.

Avoid upgrading:

“One study observed an association”

into:

“Science proves the product works.”

9. Check Sample Size & Population

Does the study population support the advertised audience?

Ask:

• How many people participated?
• Who were they?
• How were they recruited?
• What population do they represent?
• Was the sample relevant to the advertised customer?

Research involving 30 college students may not support a broad claim about all American adults.

A sample can be methodologically legitimate while still being inappropriate for a particular advertising claim.

10. Distinguish Correlation From Causation

Does the evidence show that the product caused the result?

A relationship between two variables does not automatically establish causation.

For example:

“Customers using our service had higher revenue”

does not necessarily establish:

“Our service increases revenue.”

Other differences among the customers may explain the result.

Use causal language only when the research design supports causal interpretation.

11. Review Percentage Claims

Does the percentage have a meaningful baseline?

A statement such as:

“Performance increased 100%”

may sound substantial even if the underlying measure increased from one event to two.

Whenever necessary, provide context such as:

• Starting value
• Ending value
• Sample
• Time period
• Measurement definition

Relative changes can be accurate while still producing an exaggerated impression when the baseline is hidden.

12. Review Average Claims

Does the average accurately represent typical experience?

A mean can be heavily influenced by unusually high or low values.

When stating:

“Customers save an average of $500”

determine:

• Which customers were included
• Which period was measured
• Whether non-savers were included
• Whether the median tells a different story
• Whether the result is reasonably representative

Do not select whichever statistic produces the strongest advertisement without considering whether it creates a misleading impression.

13. Review “Up To” Claims

Can a meaningful proportion of customers achieve the advertised maximum?

Claims such as:

“Save up to 50%”

or:

“Up to 12 hours of battery life”

can create expectations even though “up to” qualifies the maximum.

Determine whether the advertised maximum represents a genuine result available under reasonable conditions rather than an exceptional theoretical possibility.

The qualification should not be used to advertise outcomes almost nobody can realistically obtain.

14. Review Superlatives

Can words such as “best,” “fastest,” or “number one” be substantiated?

Review claims involving:

• Best
• Fastest
• Most effective
• Highest rated
• Leading
• Number one
• Most popular
• Most trusted

Determine:

• What is being compared?
• Which competitors are included?
• Which geography applies?
• What time period applies?
• Which metric determines superiority?

A statement such as “America’s #1 Brand” needs a clearly supportable basis.

15. Review “Only” & Unique Claims

Is the claimed uniqueness actually true?

Claims such as:

• The only
• Exclusive
• First
• One of a kind
• No other product

can be difficult to support in dynamic markets.

Verify the competitive environment before publication and consider how quickly the claim may become outdated.

16. Review Comparative Advertising

Is the comparison fair?

Comparative claims should use meaningful and reasonably comparable conditions.

Check:

• Product version
• Price
• Package size
• Test conditions
• Time period
• Audience
• Feature set
• Geography

Do not compare the advertiser’s premium model with a competitor’s entry-level model while implying a general brand superiority.

17. Identify the Comparison Clearly

Can the audience understand what is being compared?

A statement such as:

“40% faster”

is incomplete unless context makes clear:

• Faster than what?
• Under which conditions?
• Using which measurement?

The comparison basis should be understandable.

18. Use Competitor Information Accurately

Is the competitor information current?

Verify:

• Product specifications
• Price
• Features
• Availability
• Policies
• Performance

Competitor products change.

A comparison that was accurate when a campaign was planned can become inaccurate before the campaign ends.

19. Review Demonstrations

Does the demonstration reflect normal product performance?

Do not create an artificial demonstration that exaggerates capability.

Review:

• Conditions
• Preparation
• Editing
• Product quantity
• Time
• Environment
• Special equipment

If the demonstration requires unusual conditions, determine whether those conditions should be disclosed.

20. Review Before-and-After Presentations

Are the two conditions genuinely comparable?

Check whether changes in:

• Lighting
• Camera angle
• Makeup
• Clothing
• Posture
• Editing
• Retouching
• Environment

create an apparent result beyond what the product actually produced.

The visual itself may communicate a performance claim.

21. Review Product Images

Does the imagery accurately represent the product?

Images should not materially exaggerate:

• Size
• Quantity
• Color
• Features
• Included accessories
• Performance
• Appearance

This applies to photography, illustration, rendering, and AI-generated product images.

22. Review Testimonials

Is the testimonial genuine?

Confirm that the person:

• Exists
• Used the product where relevant
• Actually made the statement
• Actually experienced the result
• Has given appropriate permission

Do not fabricate testimonials or create fictional customers.

23. Review Testimonial Results

Could audiences interpret the testimonial as an expected result?

An extraordinary customer outcome can create an implied claim about what other customers may reasonably expect.

Statements such as:

“I lost 40 pounds in eight weeks”

or:

“We increased revenue 300%”

require careful review even when the individual experience is genuine.

A disclaimer such as “results may vary” should not be assumed to cure an otherwise misleading impression.

24. Review Endorsers

Is the endorsement consistent with the endorser’s actual experience?

An endorser should not claim:

• Product use that did not occur
• Results they did not achieve
• Opinions they do not hold
• Expertise they do not possess

The advertiser remains responsible for claims communicated through endorsers.

25. Disclose Material Connections

Could the audience reasonably want to know about the relationship?

Material connections can include:

• Payment
• Free products
• Affiliate commissions
• Employment
• Discounts
• Travel
• Family relationships
• Business relationships

Use clear disclosure where needed.

Related AAMA Resource: Influencer & Sponsored Content Disclosure Guide

26. Review Consumer Reviews

Are reviews authentic?

Do not use:

• Fake reviews
• AI-generated reviews presented as real customers
• Reviews from people who did not use the product
• Undisclosed employee reviews
• Purchased positive reviews

The credibility of review systems depends on audiences believing that reviews reflect genuine consumer experiences.

27. Review Incentivized Reviews

Does compensation depend on positive sentiment?

Organizations may sometimes encourage feedback through incentives, but an incentive should not be conditioned on the reviewer providing a particular sentiment where doing so would create a deceptive review practice.

Where an incentive or relationship is material, consider appropriate disclosure.

28. Review Pricing Claims

Is the advertised price the price customers can realistically obtain?

Check:

• Mandatory fees
• Shipping
• Activation
• Subscription requirements
• Minimum purchases
• Required add-ons

Avoid highlighting an attractive number while hiding unavoidable costs that materially change the offer.

29. Review Discount Claims

Is the reference price legitimate?

Claims such as:

• 50% off
• Was $199, now $99
• Save $100

depend on the validity of the comparison price.

Review whether the stated reference reflects an actual, appropriate basis rather than an artificial price created to manufacture a discount.

30. Review “Free” Claims

Is the offer genuinely free under the represented conditions?

Look for:

• Required purchases
• Shipping
• Activation fees
• Automatic enrollment
• Subscription renewal
• Conditions

A “free” claim should not conceal a material financial requirement.

31. Review Subscription Claims

Are recurring charges clear?

Confirm that customers can understand:

• Initial price
• Renewal price
• Billing frequency
• Trial duration
• Cancellation terms
• Automatic renewal

Do not allow the headline to create a one-time-price impression when the transaction actually creates a recurring obligation.

32. Review Scarcity Claims

Is the scarcity real?

Claims may include:

• Only five remaining
• Limited availability
• Selling fast
• Almost sold out

Verify that the statement is based on real inventory, capacity, or another legitimate limitation.

33. Review Deadline Claims

Does the deadline actually exist?

Claims such as:

• Ends tonight
• Sale ends Friday
• Registration closes tomorrow

should correspond to a genuine deadline.

Avoid promotions that repeatedly restart after supposedly ending.

34. Review Environmental Claims

Is the environmental benefit specific and supportable?

The FTC’s Green Guides caution against broad, unqualified claims such as “green” or “eco-friendly” because broad environmental-benefit claims can be difficult to substantiate.

Review terms involving:

• Sustainable
• Green
• Eco-friendly
• Recyclable
• Compostable
• Biodegradable
• Renewable
• Recycled
• Carbon neutral
• Non-toxic

Determine exactly what attribute is being claimed.

35. Qualify Broad Environmental Language

Does the advertisement explain the specific benefit?

Instead of:

“Eco-friendly packaging”

a more precise claim might identify the specific relevant attribute.

The claim should not suggest a larger overall environmental benefit than the evidence supports.

Third-party certifications do not eliminate the advertiser’s responsibility to substantiate claims.

36. Review Recycling Claims

Is recycling realistically available?

A product may technically be recyclable while consumers in many locations lack access to appropriate recycling facilities.

Review both the physical characteristics of the product and practical availability when making broad recycling claims.

37. Review Health & Safety Claims

Has the appropriate level of scientific evidence been obtained?

Health and safety claims deserve particularly careful review because consumers may be unable to independently assess whether the claims are true.

Examples include:

• Reduces pain
• Improves sleep
• Prevents illness
• Supports weight loss
• Clinically proven
• Safe
• Non-toxic

Use qualified scientific and legal review where appropriate.

38. Review Financial Claims

Could the advertising affect significant financial decisions?

Carefully review claims involving:

• Savings
• Income
• Investment outcomes
• Credit
• Debt
• Business opportunities
• Employment
• Financial improvement

Do not rely on exceptional customer outcomes to imply typical financial results.

The greater the potential financial consequence, the greater the need for precision and appropriate support.

39. Review AI Claims

Does the product actually have the advertised AI capability?

Claims such as:

• AI-powered
• Intelligent
• Autonomous
• Predictive
• AI-driven

can create expectations about how a product works.

Verify the actual role of AI rather than using AI terminology primarily as promotional language.

Related AAMA Resource: Responsible AI in Advertising & Marketing Guide

40. Review AI Performance Claims

Are accuracy and performance claims supported under relevant conditions?

AI performance may vary based on:

• Dataset
• User
• Language
• Context
• Model version
• Input quality

Avoid converting a narrow benchmark into a broad statement of universal performance.

41. Review Synthetic Testimonials & People

Could the audience believe a synthetic person is a real customer or expert?

AI-generated people may create implied claims about:

• Real customer experience
• Professional endorsement
• Expert qualifications
• Actual events

Do not present a synthetic testimonial as evidence of genuine customer experience.

42. Review Certification Claims

Is the certification legitimate and current?

Verify:

• Issuing organization
• Certification status
• Scope
• Expiration
• Criteria

Do not imply that a certification covers attributes or performance outside its actual scope.

43. Review Seals & Badges

Could the audience misunderstand what a seal means?

A badge can imply independent approval even when it was created by the advertiser.

Clearly distinguish:

• Independent certifications
• Industry memberships
• Awards
• Company-created labels

Visual authority can create claims even without explanatory text.

44. Review Awards

Is the award represented accurately?

Check:

• Award name
• Year
• Category
• Organization
• Product or campaign that received it

Do not transform:

“Winner in one regional category”

into:

“America’s best product.”

45. Review Survey Claims

Does the survey support the statement?

Claims such as:

“9 out of 10 customers prefer us”

require review of:

• Sample
• Question wording
• Comparison
• Population
• Timing
• Survey method

Determine whether respondents actually had experience with the products being compared.

46. Review Customer Counts

Is the denominator accurate?

Claims such as:

“Trusted by 50,000 businesses”

should clearly correspond to a legitimate definition of customer.

Do not count:

• Leads
• Free accounts
• Newsletter subscribers
• Website visitors

as paying customers unless the wording supports that interpretation.

47. Review Market Leadership Claims

Does “leading” have a defined basis?

Market leadership may be based on:

• Revenue
• Units
• Customers
• Traffic
• Market share
• Survey preference

Identify the metric internally and make sure the advertisement does not create a broader claim than the evidence supports.

48. Review Performance Time Frames

Does the advertisement specify the relevant period where necessary?

Results can change substantially depending on whether performance was measured over:

• One week
• One month
• One year
• Customer lifetime

Do not combine results from different periods in ways that create an inaccurate comparison.

49. Review Geographic Scope

Does the claim apply where the advertisement is running?

A statement may be true nationally but not within a particular state, city, or market, or vice versa.

Review:

• Availability
• Price
• Competitors
• Regulations
• Market leadership
• Service coverage

Geographic qualifications may be necessary.

50. Review Qualifying Language

Does the qualification accurately limit the claim?

Common qualifiers include:

• May
• Can
• Up to
• Selected customers
• Participating locations
• Under specific conditions

A qualifier should genuinely modify the claim rather than create the appearance of caution while leaving the misleading impression unchanged.

51. Review Disclosures

Is every material disclosure clear and conspicuous?

Review:

• Placement
• Size
• Contrast
• Language
• Timing
• Duration
• Proximity

A disclosure should be reasonably noticeable and understandable.

Do not assume that placing information somewhere on the page automatically makes it effective.

52. Do Not Use Fine Print to Reverse the Claim

Does the disclosure contradict the prominent message?

For example:

Headline: “No Fees”

Fine print: “Required $49 processing fee.”

The qualification cannot reasonably repair a fundamentally contradictory headline.

Rewrite the main claim when the qualification changes its essential meaning.

53. Review Visual Disclosures

Can the disclosure be read in the actual advertisement?

Check disclosures within:

• Images
• Stories
• Display ads
• Video
• Mobile layouts
• Outdoor advertising

Review the final rendered format rather than the design file alone.

54. Review Audio & Video Disclosures

Does the audience have enough time to notice and understand the disclosure?

A disclosure appearing for a fraction of a second may provide little meaningful information.

For important video claims, consider whether both visual and spoken communication are appropriate.

55. Review Mobile Presentation

Does the claim remain accurate after mobile truncation?

Mobile displays can remove:

• Qualifiers
• Disclosures
• Supporting language
• Comparison context

Review the actual mobile experience.

A compliant desktop layout can create a misleading mobile presentation if essential information disappears below a break or outside the visible frame.

56. Review Headlines Separately

Could someone seeing only the headline receive a misleading impression?

Many audiences encounter advertising quickly.

Do not rely entirely on body copy to correct an overly broad headline when the headline is likely to be consumed independently.

57. Review Social Media Copy

Does short-form copy preserve necessary context?

Character limits do not eliminate responsibility for accurate claims.

If a claim requires so much qualification that it cannot be communicated responsibly within the format, reconsider the claim or format rather than hiding the qualification elsewhere.

58. Review Search Advertising

Does the search ad accurately describe the destination?

Search ads often communicate within very limited space.

Ensure that:

• Price claims are accurate
• Offer claims match the destination
• Availability is current
• Headline combinations do not create unintended claims

Dynamic assembly should be reviewed because automated combinations can create statements no one explicitly wrote.

59. Review Dynamic Advertising

Can automated combinations create unsupported claims?

Responsive and dynamically generated advertising can combine:

• Headlines
• Descriptions
• Products
• Prices
• Locations
• Images

Review possible combinations rather than approving each individual asset in isolation.

60. Review Personalization

Does personalization alter the claim?

A personalized advertisement may create stronger implications than the generic version.

For example:

“People like you save $500”

may imply evidence about a specific audience segment.

Verify that personalization logic and supporting data justify the resulting statement.

61. Review Omissions

Is important information missing?

An advertisement can mislead through omission as well as false statements.

Ask whether the audience needs additional information to understand:

• Price
• Limitations
• Eligibility
• Risk
• Subscription
• Performance
• Conditions

If omission materially changes how the offer would be evaluated, additional disclosure or rewriting may be necessary.

62. Check the Landing Page

Does the destination preserve the claim accurately?

The advertisement and landing page should be reviewed together.

Confirm that:

• Pricing matches
• Offer matches
• Product matches
• Qualifications match
• Availability matches
• Claims remain consistent

A truthful advertisement can still produce a misleading customer journey when the destination materially changes the offer.

63. Maintain a Claims File

Is supporting documentation organized and retrievable?

For significant claims, preserve:

• Evidence
• Research
• Methodology
• Data
• Source documents
• Approval records
• Disclosures
• Review notes
• Relevant dates

A claims file helps future teams understand why the statement was approved.

It also makes re-review easier when campaigns are reused.

64. Assign a Claim Owner

Who is responsible for verifying the claim?

Responsibility may belong to:

• Marketing
• Research
• Product
• Legal
• Compliance
• Analytics
• Agency

Do not allow everyone to assume that someone else checked the evidence.

65. Establish Expiration or Review Dates

Could the claim become outdated?

Claims involving:

• Prices
• Customer counts
• Market leadership
• Competitors
• Rankings
• Product specifications
• Certifications

may require periodic review.

Record when important claims should be revalidated.

66. Final Claims Review

Before publication, confirm:

• Every express claim has been identified
• Reasonable implied claims have been considered
• Overall net impression is accurate
• Objective claims have prior substantiation
• Evidence matches the exact claim
• Evidence quality is appropriate
• Research claims accurately describe the research
• Percentages contain sufficient context
• Average claims are representative
• Superlatives are supportable
• Unique claims are current
• Comparisons are fair
• Competitor information is current
• Demonstrations are representative
• Before-and-after presentations are fair
• Testimonials are genuine
• Endorsements reflect actual experience
• Material connections are disclosed
• Reviews are authentic
• Pricing claims are accurate
• Discount claims use legitimate reference prices
• Free claims accurately describe the conditions
• Recurring charges are clear
• Scarcity and deadlines are genuine
• Environmental claims are specific and supported
• Health and safety claims received appropriate review
• Financial claims are appropriately supported
• AI claims reflect actual capabilities
• Certifications and awards are represented accurately
• Surveys support the advertised conclusion
• Customer counts use valid definitions
• Geographic and time limitations have been considered
• Qualifiers genuinely limit the claim
• Disclosures are clear and conspicuous
• Fine print does not contradict the headline
• Mobile and channel-specific presentations have been reviewed
• Automated advertising combinations have been checked
• Material omissions have been considered
• Landing-page messaging matches
• Supporting documentation is archived
• An accountable reviewer has approved the claim

If a material claim cannot be supported, the correct response is to revise or remove the claim rather than weaken the review standard.

Review Claims Before Creative Becomes Expensive

Claims review should begin before final production.

A campaign becomes more difficult and expensive to change after:

• Video has been filmed
• Photography has been completed
• Media has been purchased
• Packaging has been printed
• Influencers have been contracted
• Landing pages have been built

Strategists, copywriters, account teams, researchers, and legal or compliance professionals should identify high-risk claims during concept and copy development.

Early substantiation can also improve creative work because the strongest verified evidence often becomes the most persuasive advertising material.

Evidence Makes Advertising Stronger

Claims review should not be treated only as a restriction on creativity.

Specific, supportable evidence can produce better advertising than vague superlatives.

Instead of:

“We’re the best solution.”

evidence may allow:

“Customers completed the process 37% faster in our 2026 controlled test.”

The second statement gives audiences something meaningful to evaluate.

Responsible substantiation can therefore improve credibility, differentiation, strategy, and persuasion at the same time.

Related AAMA Resources

Continue reviewing advertising with the Advertising Ethics Guide, Advertising Copy Review Checklist, Influencer & Sponsored Content Disclosure Guide, Responsible AI in Advertising & Marketing Guide, Marketing Research Methods Guide, How to Design a Marketing Survey, Marketing Metrics & KPI Reference, Landing Page Evaluation Checklist, and Marketing Data Ethics Checklist. These resources provide additional guidance for evaluating evidence, endorsements, research, disclosures, copy, digital experiences, and responsible professional practice.

The AAMA Resource Library will continue reviewing this checklist as advertising law, regulatory guidance, technology, industry practice, and professional standards evolve.