If I work with an influencer or a KOC, do I have to label the post as sponsored?

Yes. In 2021, the Taiwan Fair Trade Commission issued its Guidelines on the Disclosure of Digital Advertising and Influencer Endorsements, which explicitly require that any paid arrangement — money, free products, discounts, travel, or consideration in any other form — be disclosed within the post itself. Disclosure can take the form of plain text ("sponsored," "advertisement," "brand partnership," "gifted product") or a hashtag (#ad #sponsored #paidpartnership). Failing to disclose can trigger an unfair competition investigation under Article 25 of the Fair Trade Act.

Do I need to disclose sponsorship when posting word of mouth on PTT?

Legally, yes — but PTT's community culture makes execution more complicated. Board rules, the Fair Trade Act's disclosure requirement, and PTT users' finely tuned radar for sponsored content squeeze word-of-mouth work from three directions at once. The approach that is both compliant and effective is to write in the form of a genuine experience report and, where there is a paid arrangement, add a short line at the end noting that the product was supplied by the brand for trial — rather than stamping the post with an obvious "sponsored post" label, which is far more likely to get it deleted by a moderator.

Which word-of-mouth tactics are clearly illegal in Taiwan?

Several practices cross the line unambiguously: 1) posing as an ordinary consumer to post false reviews (Article 21 of the Fair Trade Act); 2) using fake accounts to inflate Google Maps ratings (a violation of Google's terms of service and potentially unlawful); 3) claiming unapproved therapeutic effects in health food or medical advertising (the Health Food Control Act and the Medical Care Act); and 4) failing to disclose paid endorsements (the digital advertising disclosure guidelines). Each of these has produced real enforcement cases and fines from the Fair Trade Commission.

Word-of-Mouth Marketing Compliance in Taiwan: The Fair Trade Act, Disclosure Duties, and Platform Rules

The legal gray area around word-of-mouth marketing in Taiwan is a lot narrower than most brands assume.

Not every kind of buzz is fair game. Since the Fair Trade Commission published its digital advertising disclosure guidelines in 2021, the compliance requirements for word-of-mouth marketing in Taiwan have become considerably more explicit. Understanding where those boundaries sit is a precondition for doing this work at all.

The core regulatory framework

The Fair Trade Act (Articles 21 and 25)

Article 21 governs false advertising and misleading representations: a business may not make false or misleading representations about its goods or services. Paying people to pose as consumers and publish untrue reviews falls squarely within this article.

Article 25 governs “other deceptive or obviously unfair conduct sufficient to affect trading order.” A paid endorsement that does not disclose the commercial relationship — leaving consumers to believe they are reading an independent, objective assessment — has been held to constitute deceptive conduct.

Penalties for violating the Fair Trade Act range from NT$50,000 to NT$25 million, and in serious cases the authorities can order a suspension of operations.

The Fair Trade Commission’s Guidelines on the Disclosure of Digital Advertising and Influencer Endorsements (2021)

These guidelines are currently the most direct legal reference point for word-of-mouth marketing in Taiwan. The core requirements are as follows.

What triggers the duty to disclose

If the sponsoring party (the brand) provides consideration of any kind — cash, a free product, a discount code, complimentary services, a sponsored trip — to a creator or a word-of-mouth participant, the resulting content carries a disclosure obligation.

How the disclosure must be made

The disclosure must be clearly visible. It cannot be set in tiny type or buried inside a wall of hashtags.
It must appear in a prominent position: within the first two lines of an Instagram caption (where it will not be cut off behind the “more” link), or in the title or the first 30 seconds of a YouTube video.
Verbal disclosure — stating it out loud in a YouTube video — counts, but pairing it with on-screen text is far safer.

Common forms of correct disclosure

Plain text: “This post is a sponsored brand partnership,” “This article contains paid promotional content,” “Trial review (product supplied by the brand).”
Hashtags: #sponsored #ad #brandpartner — but a hashtag is easily lost in a crowd of other tags, so it is better to pair one with a written statement.

Category-specific regulations

Food and health supplements

Under Taiwan’s Act Governing Food Safety and Sanitation, food advertising may not claim medical efficacy (for example, “cures insomnia” or “improves diabetes”). Word-of-mouth content is bound by the same limitation: a consumer writing up their experience can describe how they felt, but cannot frame it as a therapeutic claim.

The Health Food Control Act goes a step further. Only foods that have passed review and obtained a Health Food certification number may claim specific benefits, and then only within the statutory scope of the approved function. Ordinary foods — a category that covers a great many of the supplements on the market — may not claim any health benefit at all.

Medical services and aesthetic medicine

Article 86 of the Medical Care Act prohibits medical advertising from using language that guarantees results or asserts superiority (“the highest standard”), and bars the use of patient testimonials or before-and-after photographs in advertising without approval from the competent authority.

Within a word-of-mouth post, there is a meaningful difference between a consumer describing their own experience (“I had hyaluronic acid filler and I was happy with the result”) and a guarantee of efficacy (“this clinic guarantees results”). The first is a personal statement; the second breaks the law.

Compliance in practice, platform by platform

PTT

PTT — Taiwan’s largest and longest-running online bulletin board — has no built-in mechanism for sponsorship disclosure, but individual board rules typically prohibit undisclosed sponsored posts outright.

Practical recommendations for staying compliant on PTT

Have real people with genuine firsthand experience write the post. Do not use farmed or purchased accounts.
Keep the content centered on personal experience and avoid promotional language.
Where there is a paid arrangement, add a line at the end acknowledging it (for example, “Thanks to [brand] for providing the trial product”).
Make sure the account holder is available to answer follow-up questions in the comments. If they cannot field specific questions about using the product, readers will conclude they never used it.

Dcard

Dcard — a community platform hugely popular with students and young professionals in Taiwan — requires posts to include a #廣告 (ad) or #業配 (sponsored) hashtag in the title or body. Moderators can delete posts that fail to do so.

Instagram

Under Instagram’s platform rules, the Paid Partnership label is the officially recommended disclosure method, and it also satisfies the Fair Trade Commission’s requirements. Stories offer an equivalent paid-partnership tag that names the advertiser.

YouTube

YouTube’s policies require creators to check the “contains paid promotion” box in the video settings for any video that includes paid promotional content, and recommend a verbal disclosure at the start of the video. Leaving the box unchecked can lead YouTube to apply the paid-promotion disclosure itself or to remove the video outright.

Google Maps

Google’s policies explicitly prohibit:

Restaurant or business owners reviewing their own listings
Offering money or discounts in exchange for positive reviews
Competitors leaving negative reviews on rival listings
Using fake accounts or paid services to inflate ratings

Reviews that violate Google’s policies may be deleted, and in serious cases Google will attach a warning to the business listing indicating that its reviews may have been manipulated — far more damaging than any ordinary negative review.

Operating principles for compliant word of mouth

The test to apply: for any word-of-mouth post, a reader should be able to tell at a glance whether it is the product of a paid arrangement. If the disclosure leaves consumers feeling misled, it has not done its job.

Authenticity is the best protection: the regulations target word of mouth that deceives consumers. Real customers sharing real experiences remain compliant even where consideration such as a free product is involved, so long as it is disclosed. The key to running word-of-mouth marketing compliantly is making sure every KOC who posts has genuinely used the product and is describing how they actually felt — rather than reciting a script written by the brand.

Keep records: partnerships with KOCs and KOLs should be documented in a written agreement covering disclosure obligations, the scope of usage rights, and compliance requirements. If a legal question arises later, that agreement is your strongest evidence.

Compliance in word-of-mouth marketing is not there to restrict you; it is there to protect you. Genuine, properly disclosed word of mouth is the only kind that compounds into a durable brand asset — and the only kind the regulations are designed to protect.

If you have questions about the compliance of your brand’s word-of-mouth strategy, or you need a framework for word-of-mouth work that meets the regulatory requirements, talk to a NETVANA consultant. We build compliance considerations into the design of every word-of-mouth program we run.

Further reading: to learn how to assess an agency’s compliance practices when choosing a partner, see How to Choose a Word-of-Mouth Marketing Agency: A Complete Guide to Avoiding Bad Actors. For the full foundations of the discipline, see The Complete Guide to Word-of-Mouth Marketing. For the details of negotiating sponsorship fees and usage rights, see The Complete Guide to Influencer Pricing in Taiwan. And for the misconceptions that trip brands up most often, see Seven Myths About Word-of-Mouth Marketing.