FTC weighs rules for platforms that optimize impersonation ads

The Federal Trade Commission is considering whether online platforms should face new obligations when their own advertising tools help present or target deceptive impersonation ads. The agency’s rulemaking inquiry reaches beyond advertisers who submit misleading promotions to examine how platforms create, assemble or decide who sees them.

That could bring search engines’ ad-assembly and optimization practices into closer scrutiny. In the FTC matter involving bill-payment service Doxo, an advertiser allegedly used search ads that impersonated billers. A court recounted testimony that a search engine assembled displayed headlines from as many as 15 elements supplied by the advertiser, rather than showing text and an arrangement dictated entirely by that advertiser.

The inquiry does not itself establish liability for platforms. The FTC enforcement matters it cites were brought against advertisers and others, not against platforms for carrying their ads. The agency is seeking evidence on how platform tools work, how they are misused and what controls might cost.

What platform conduct is under review?

The FTC defines platforms as public-facing websites or apps where third parties offer goods, services or opportunities through paid ads or other listings. That could cover search engines, social networks, online marketplaces, app stores, employment services, travel platforms and classified sites. The definition includes no size threshold.

The agency is weighing rules focused on how platforms create or alter ad content, assemble ads from advertiser-provided elements, and select the audience or timing. The inquiry also asks about sham profiles, non-advertising content and deceptive ads that do not involve impersonation. It leaves open whether a platform would need to know, or have reason to know, about a specific violation—and considers duties that could apply before such knowledge.

What evidence has the FTC cited?

The FTC points to Consumer Sentinel data showing more than 1 million imposter reports of all kinds and nearly $3.5 billion in reported losses in 2025. It also cites $2.1 billion in losses from scams that began on social media, a total that includes all types of scams, not only impersonation.

The inquiry’s evidence about platforms’ specific role is less developed. FTC staff said complaints it reviewed did not describe how platform tools optimized the ads. The proceeding also does not estimate platform revenue from impersonation ads, the costs platforms already incur to address scams, or how added screening could affect lawful advertisers whose ads are wrongly blocked. Those questions are among the issues the agency is asking commenters to address.

This report draws on information from www.hlc.com.