Guidelines 13 explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
Guidelines 13 to 15 deal with the people who lend their name to an advertisement. An endorsement must reflect a genuine and reasonably current opinion based on adequate information or experience. Professionals barred from endorsing in India cannot be replaced by foreigners from the same profession. A connection with the brand that the audience would not expect must be fully disclosed. The Central Authority's decision is final in case of a dispute about interpretation.
The guidelines were issued by the Central Consumer Protection Authority (CCPA) on 9 June 2022 under section 18 of the Consumer Protection Act, 2019. This article takes them as amended up to 3 October 2026 (no amendment listed by the CCPA). Later amendments should be checked on the CCPA website. The CCPA has also issued advisories and know-hows on endorsements; they are separate documents and are not covered here, so check the CCPA website for them.
An endorsement must reflect the endorser's genuine, reasonably current opinion, be based on adequate information or experience, and not otherwise be deceptive. Where Indian professionals are barred by law from endorsing in advertisements, foreigner professionals of that profession are barred too. A connection with the brand that might materially affect the value or credibility of the endorsement and is not reasonably expected by the audience must be fully disclosed. The Authority's decision on interpretation is final. Endorsers who breach face consequences under the Act; read section 21.
Brands, agencies and creators who run endorsement campaigns can ask for compliance advisory support on disclosure wording and contracts before posting.
Who is an endorser
Guideline 2(1)(f) defines "endorser" to include an individual, a group or an institution making an endorsement of any goods, product or service in an advertisement whose opinion, belief, finding or experience is the message that the advertisement appears to reflect. A film actor, a doctor, a social media creator, a sports club and an industry association can all be endorsers. The definitions are explained in the article on guidelines 1 to 3.
Guideline 13(1): the due diligence test
"Any endorsement in an advertisement must reflect the genuine, reasonably current opinion of the individual, group or organisation making such representation and must be based on adequate information about, or experience with, the identified goods, product or service and must not otherwise be deceptive."
The sentence has four tests.
| Test | Meaning in practice |
|---|---|
| Genuine opinion | The endorser actually holds the view expressed |
| Reasonably current | The opinion is not stale; an endorsement of a product that has since changed may no longer reflect the endorser's opinion |
| Adequate information or experience | The endorser knows the product through information or use, not only through a script |
| Not otherwise deceptive | The endorsement as a whole must not mislead |
An invented example: a creator, Arjun, records a video praising a protein powder after a one-day trial. Eight months later, the brand changes the formula and keeps running the old video. The opinion is no longer "reasonably current" for the new product, and the endorsement risks being deceptive. A careful creator would try the current product and re-record.
The primary duty to check the endorsement lies with every party involved: the advertiser and the agency also have duties under guideline 12(d), explained in the article on guideline 12.
Guideline 13(2): professionals barred from endorsing
Where "Indian professionals, whether resident in India or otherwise, are barred under any law for the time being in force from making endorsement in any advertisement pertaining to any profession, then, foreigner professionals of such profession shall also be not permitted to make endorsement in such advertisement."
The Explanation says "foreigner professional" means a person who is not a citizen of India. So an advertisement cannot get around a professional's bar on advertising by using a foreign member of the same profession. The guideline names no profession and no law. The professional rules concerned sit in other laws, which a campaign team should check.
Guideline 14: material connection
"Where there exists a connection between the endorser and the trader, manufacturer or advertiser of the endorsed product that might materially affect the value or credibility of the endorsement and the connection is not reasonably expected by the audience, such connection shall be fully disclosed in making the endorsement."
Three elements must be present before the duty to disclose arises:
- a connection between the endorser and the trader, manufacturer or advertiser;
- the connection might materially affect the value or credibility of the endorsement; and
- the audience would not reasonably expect it.
The disclosure must be "full" and made "in making the endorsement", not afterwards. Examples of connections that an audience may not expect include payment, supply of the product without charge, a share in the business or a family relationship. The guideline does not list them, and the examples are illustrations only.
An invented example: a fitness influencer, Neha, recommends a supplement brand in a reel. She is also a paid brand ambassador. An audience would not necessarily expect this, and it affects credibility. Neha must disclose the paid connection in the reel itself. If she says nothing, she risks breaching guideline 14. Where the audience would reasonably expect the connection, the third element is not met, though a careful brand will disclose in any case.
For wider checklists on influencer compliance, see the post on the compliance checklist for influencers. For tax questions about influencer income, see our income-tax guides.
Guideline 15: interpretation
"In case of any ambiguity or dispute in interpretation of these guidelines, the decision of the Central Authority shall be final." The guidelines therefore give the Authority the last word on what they mean.
Consequences
The guidelines are issued under section 18(2)(l) of the Act, and contravention is dealt with under the Act. The article on section 21 explains the Authority's power to penalise endorsers and its other powers; the articles on sections 88 and 89 cover non-compliance with directions. This article quotes no penalty amount.
A short checklist for endorsers and brands
- Use the product or service, or have adequate information about it, before endorsing.
- Re-check the endorsement if the product changes.
- Say only what you actually believe.
- Disclose any material connection that the audience would not expect, in the endorsement itself.
- If you belong to a profession that is barred from endorsing, do not appear in an advertisement for a product from that field, and brands should not hire a foreign professional of the same field to do it.
- Keep contracts and records that show what the endorser was told and shown.
Need help with an endorsement or influencer campaign?
Endorsement contracts, scripts and disclosure labels are easiest to fix before a campaign launches. Our compliance advisory team can review the contract, the script and the placement of the disclosure against guidelines 13 and 14.
Key takeaways
- An endorsement must reflect the endorser's genuine, reasonably current opinion, with adequate information or experience, and not be deceptive.
- Foreign professionals of a profession cannot endorse where Indian professionals are barred by law.
- A material connection that the audience would not reasonably expect must be fully disclosed in making the endorsement.
- The Authority's decision on interpretation is final.
- Consequences are under the Act.
Read next
- Guideline 12: duties of manufacturer, service provider, advertiser and agency
- Guidelines 1–3: definitions and application
- Complete compliance checklist for influencers in India
- Section 21: false or misleading advertisements and penalties
Disclaimer: Based on the rules, regulations and guidelines named above as published in the Gazette of India or on the CCPA website, with the amending notifications the article names (consulted on 3 October 2026). Later amendments, the Consumer Protection Act, 2019 provisions referred to, State rules and CCPA advisories should be checked. This article is general information, not legal advice; check the official text before acting.
