This is Not An #Ad: Political Influencers, Elections, and Information Integrity on Social Media

The rise of political influencers is among the latest ways that digital technology has changed how campaigns interact with voters and how voters engage with politics. CDT’s research in this area is designed to illuminate how the application of public and company policy to political influencers may affect the resilience of our democracy. To do that, it is necessary to more precisely define the category of political influencers and to understand the complexities they bring to the information and electoral environment.

Though the importance of social media personalities in politics had been growing for years, the shift towards political influencers as a mainstay of campaigns became apparent in 2020, when Michael Bloomberg’s campaign team hired meme accounts on Instagram to promote his candidacy and the Trump campaign paid $1.8 million to influencer marketing groups. By 2024, the creator economy was inextricable from elections. During that election cycle, dubbed “the influencer election” in numerous outlets, the RNC and DNC hosted dozens of influencers, political campaigns and political action committees (PACs) spent millions of dollars buying influencer posts with little transparency, and over a fifth of Americans regularly got their news from social media influencers. 

Despite their prevalence in modern campaigning and the online information ecosystem, there is no common understanding of what a political influencer is or how to situate them in the landscape of political advertising, journalism, activism, and free speech online. Their role raises legal questions as well highlighting tensions in social media company policies. Studying political influencers and identifying potentially applicable laws and policies — as well as gaps that may need to be filled — is a necessary but underexplored avenue for supporting democratic election processes and information integrity. 

Academic literature identifies subcategories of political influencers: politicians acting as influencers, influencers acting as opinion leaders, influencers who become politicians, and journalists acting as political influencers. The most amorphous group, and the one in which CDT is principally interested, is influencers who act as opinion leaders online. They embody a grey area of political influence and regulation, whereas politicians and traditional media have more expressly established legal protections and constraints. 

“Opinion leaders” still constitutes a broad group that can flatten the diverse ways that this subset of political influencers engage online. CDT is focused on the opinion leaders who gained their following through social media influencing, in contrast to celebrities or other internet personalities who may act as opinion leaders but earned their notoriety through a different industry. Some members of this subset host wildly successful podcasts or have more social media followers than prominent traditional journalists. Others might be better described as engaging in activism, and still others intersperse their unrelated lifestyle or cultural content and brand deals with political partnerships. They may share unpaid or paid political content. Moreover, the payment binary does not account for the full complexity of the influencer business model, which often involves platform-based content monetization, exclusive access, experiences, and gifts.

When does an account cross the line from regular political speech into something worthy of more attention? The purpose of most political speech, after all, is to influence others — either to vote, to support a cause, or to join a movement. The Supreme Court has repeatedly recognized that speech about matters of public concern occupies the “highest rung” of our First Amendment values, while also acknowledging that the government has compelling interests in regulating political speech in certain circumstances. The emergence of influencers raises complex questions about where the lines of regulated and unregulated political speech may fall. Appropriately parsing these differences is necessary to understand the full scope of political influence online and situate political influencers among the full range of people participating in public discourse and our democracy.

Political influencers exist in a liminal regulatory space, adjacent to legal frameworks which may or may not apply, depending on each influencer’s approach and individual circumstances:

• Existing commercial guidance: In 2019, the Federal Trade Commission (FTC) published a guide for disclosures by social media influencers, which explains how its Endorsement Guides apply to brand and product recommendations. The Endorsement Guides were updated in 2023 and included clarification of how and when online actors are endorsers and tags on social media are considered endorsements. Whether and how the FTC’s guidance should apply to political influencers, however, remains unclear.
• Election law and campaign finance: When candidates, parties, and PACs pay for influencer posts, political influencing may be subject to campaign finance law. One study last year found that over a quarter of US creators were solicited by political organizations during the 2024 election. It is difficult to trace these transactions, however. Influencers are not legally required to disclose these partnerships, and their names don’t necessarily show up in Federal Election Commission (FEC) filings, in part due to the important role of middlemen, namely marketing agencies that political entities hire to manage influencer outreach and strategy. Additionally, the diverse influencer business model, in which clout and algorithmic appeal feature heavily, raises the question of whether and how non-financial remuneration should play into political influencer governance. FEC leadership has disagreed about political influencer governance in the past. In 2023, Commissioners Ellen Weintraub and Shanna Broussard issued a statement expressing disappointment that the Commission’s updated rules did not “address the ever-increasing phenomenon of social media influencers who are paid to create or share political content.” 
• Lobbying regulation and foreign influence: Regulations and norms related to lobbying may apply to or serve as points of comparison for political influencer governance. One of the most prominent recent political influencer scandals occurred in fall 2024 when it was revealed that six American influencers were allegedly paid for political content as part of a Russian influence operation. The Department of Justice indicted two Russians behind the scheme for violating the Foreign Agents Registration Act, which is intended to provide transparency around representing the interests of a foreign government. 

Social media company policy can be just as ambiguous as applied to political influencers as the regulatory areas discussed above. Three key policy areas include:

• Political advertising: Platforms have a range of policies related to political advertising, as CDT documented last year in Rules of the Road: Political Advertising on Social Media in the 2024 U.S. Election. Social media platforms do not have a consistent definition of what constitutes a political ad, including whether the policy covers paid influencer posts. Policies range from permissive (X does not require “paid for” disclosures on political ads) to strict (TikTok does not permit political ads). Regardless of the specific policy, insufficient enforcement allows some actors to circumvent platform policies. A 2021 Mozilla Foundation report found that loopholes and weak enforcement of TikTok’s ban on political advertising (which includes political branded content from influencers) sometimes failed to account for paid political content on the platform. While political ads should in theory be created and run through social media companies’ advertising platforms, influencer content may fall into loopholes or evade detection. 
• Sponsored or branded content: Sponsored or branded content is an important way that influencers make money. While different platforms have different terms and policies, there are generally two categories of these influencer-entity partnerships, distinguished by whether a collaboration between the influencer and their partner occurs through the platform’s infrastructure (on-platform) or independently (off-platform). Company policy can be more easily tailored to the former, while off-platform partnerships are far more difficult to monitor for compliance
• On-platform monetization: Some social media platforms offer on-platform monetization programs for prominent accounts, where creators are paid for their posts in some form, including through ad revenue, subscriptions, or for views and engagement. A study of political influencers in Global Majority countries found that influencers’ political content had 50-70 percent higher engagement than their non-political content. Other research found that of 9 popular YouTubers, 37 percent of the most highly viewed videos mentioned voting or elections. These findings underscore that audiences are interested in political content from influencers and that political content can be part of the influencer business model, even in the absence of formal sponsorship. Increased views and engagement driven by political content can drive up revenue from on-platform monetization, as well improve metrics that influencers use to gain lucrative brand deals. In other words, influencers producing political content have a symbiotic relationship with social media platforms looking to increase user engagement.