On 24 September 2026, the U.S. Federal Trade Commission (FTC) voted 2–0 to seek public comment on whether its Impersonation Rule should be expanded to address the role digital platforms may play in distributing impersonation scams through their advertising tools.

The move does not change the law today. It starts a rulemaking process that could eventually change how platforms are treated when their advertising systems are used to distribute fraudulent impersonation content.

For brands, executives and creators dealing with impersonation, the question is significant: who is responsible when a fake account is not simply created, but actively promoted to a targeted audience?

What is the FTC proposing?

The FTC has issued an Advance Notice of Proposed Rulemaking (ANPRM) asking for information about whether the Impersonation Rule should be updated to address digital platforms and their advertising tools.

The FTC's existing Impersonation Rule addresses deceptive impersonation of governments and businesses. The new notice asks whether the rule should also address the role of platforms whose advertising and optimisation systems can be used to distribute impersonation scams.

The FTC has not proposed a final rule.

It has also not found that any particular platform has violated the law, named a company as a respondent or announced an enforcement action against a platform in connection with the announcement.

Instead, the Commission is asking businesses, consumers and other interested parties to provide information that could help determine whether additional rules are necessary.

The public comment period will run for 60 days after the notice is published in the Federal Register.

Why platform advertising matters in impersonation scams

The problem with impersonation is not limited to the creation of fake accounts.

A fake account with no audience may have limited reach. A fake account supported by paid advertising can be placed in front of a carefully selected audience at scale.

That distinction matters.

Digital advertising systems are designed to identify and reach specific audiences. The same infrastructure that helps legitimate businesses find potential customers can potentially be used by bad actors to distribute fraudulent content.

For an impersonator, that could mean using a familiar brand name, logo, executive identity or creator profile to make a scam appear legitimate and then paying to put that content in front of people who are more likely to engage with it.

The FTC's announcement specifically raises this question of platform responsibility.

Bureau of Consumer Protection Director Christopher Mufarrige said impersonation scams are being "amplified by digital platforms that profit from them."

The FTC estimates that Americans reported $3.5 billion in losses to impersonation scams in 2025.

That figure represents reported losses collected by the FTC. It does not represent the total amount lost to impersonation scams, as many incidents are never reported.

The visibility problem for brands

There is another problem that is easy to overlook: a brand cannot necessarily see the impersonation its audience is seeing.

When an impersonator runs a paid campaign, the advertisement may be targeted to a particular group of users, location or demographic.

The legitimate brand may never encounter the advertisement in its own feed.

That creates an unusual monitoring problem. A company can have customers receiving fraudulent advertisements using its name or identity without anyone inside the organisation seeing the content organically.

This is one reason paid impersonation can be particularly difficult to detect.

The content is not necessarily waiting for someone to search for it. It is being distributed directly to an audience.

What the FTC announcement does and does not change

For organisations dealing with impersonation today, the practical position remains largely unchanged.

The FTC's announcement is the beginning of a potential rulemaking process, not the end of one.

It does not currently:

• create new legal obligations for advertising platforms;

• establish that a platform is liable when an impersonation scam appears in its advertising system;

• require platforms to remove specific impersonation content;

• create a new compensation mechanism for affected brands; or

• guarantee that the FTC will ultimately introduce a new rule.

Those questions will depend on the information received during the rulemaking process and any subsequent action by the Commission.

For brands, that means there is little reason to wait for regulation before improving how impersonation is detected and removed.

What brands and executives can do now

There are several practical steps organisations can take while the regulatory process develops.

1. Monitor advertising libraries

Major platforms provide searchable advertising libraries that can reveal paid advertisements that may not appear in your own feed.

Search for:

• your company name;

• product and service names;

• executive names;

• common misspellings;

• brand slogans;

• variations of your social handles; and

• commonly used scam language associated with your brand.

This provides a different view of your brand's online presence than monitoring your own social feeds.

2. Measure your removal time

Detection is only one part of the problem.

Track the time between:

discovery → reporting → platform response → removal

This gives you a measurable view of how exposed your organisation is.

It can also reveal where delays occur. A platform may acknowledge a report quickly but take considerably longer to remove the content. Another platform may remove one piece of content while leaving associated accounts, domains or advertisements active.

Without measuring the process, those gaps are difficult to see.

3. Distinguish delisting from removal

Search visibility and content removal are not the same thing.

Delisting can prevent a page from appearing in search results while leaving the underlying content online.

That distinction matters particularly for paid impersonation.

A fraudulent advertisement does not need to rank in search results. It can reach its audience through the platform's advertising system without ever appearing in a conventional search.

For that reason, an effective impersonation response needs to consider where the content is hosted and how it is being distributed, not simply whether it appears in search.

How Ceartas approaches impersonation

Ceartas monitors the internet for impersonating accounts, pages, listings and advertisements affecting brands, executives and creators.

When potential impersonation is identified, the focus is on getting the underlying content removed rather than simply reducing its visibility in search.

That can involve working with the platform or host responsible for the content, as well as following up when content reappears elsewhere.

This matters because impersonation is rarely a one-off problem. Once a particular identity or brand has been used successfully, the same material can reappear through a different account, URL or platform.

Removal therefore needs to be treated as an ongoing process rather than a single report.

The FTC's announcement may eventually change how platforms are expected to respond to this type of abuse.

For organisations dealing with impersonation today, however, the operational challenge remains the same: find the content, establish where it is being distributed, report it to the right party and keep monitoring for what appears next.

The regulatory question may take months or longer to resolve. However, the fake advertisement does not have to wait. If you are looking for immediate action to detect and address impersonation, see how Ceartas automates the search, reporting and removal of impersonating content at scale.

Source: U.S. Federal Trade Commission, 24 September 2026.