A recent Facebook Platform Policy change may affect the way many promotions are run on Facebook.  The change, effective November 5, 2014, prohibits Facebook Page owners from requiring a user to “like” their Page in order to access content, such as entry into a contest or sweepstakes, via a Facebook application (“App”).  Advertisers often use this technique, known as “like-gating,” as a way to increase the amount of likes their Pages receive. 

Facebook believes that a prohibition on like-gating will benefit both advertisers and consumers.  In announcing the change, Facebook stated in a blog post: “[T]o ensure quality connections and help businesses reach the people who matter to them, we want people to like Pages because they want to connect and hear from the business, not because of artificial incentives.” 

A like can be valuable to an advertiser, regardless of whether it is generated organically or artificially. When a user likes a Facebook Page, the like may appear on the user’s Timeline, stories from the Page may show up on the user’s news feeds, and users may also appear in advertisements for that Page.

While the implications of the change are yet to be seen, here are a few things that advertisers should keep in mind:

  • The new prohibition is part of the Facebook Platform Policy that applies to Apps on Facebook Pages.  Facebook’s Page Terms require that all Page Apps comply with the Platform Policy.  Although Facebook has not yet updated its Page Terms to prohibit like-gating for on-Page promotions that don’t use Apps, advertisers – given Facebook’s rationale for the Platform Policy change, and given the FTC’s recent guidance on social media promotions – should not be surprised to see Facebook amend its Page Terms even further to address incentivizing likes for on-Page promotions and other benefits, such as discounts or free items.   
  • For now, though, if an advertiser plans to run a Facebook promotion via an App that will extend past November 4, 2014, the advertiser should no longer require a Facebook user to like its Page in order for the user to participate.   
  • The prohibition on like-gating applies to all content provided by an advertiser via an App – not just an entry into a contest or sweepstakes.  Thus, if an advertiser is offering songs, brochures, or any other custom content where access is through an App, it should not require a user to like its Page in order to download or access this content.  
  • Although incentivizing Page-likes will be prohibited, advertisers are still permitted to incentivize users in other ways, such as to log in to the advertiser’s App, enter a promotion through an App, and check-in to a location via an App. 

Facebook's Platform Policy change is just another reminder that the terms and conditions of using social media platforms such as Facebook, Twitter, Instagram, Pinterest and the like are constantly evolving.  In order to ‎take advantage of the opportunities presented in social media, advertisers, agencies and mobile app developers must stay abreast‎ of these changes and ensure their activities remain in compliance with the applicable platform's terms and conditions of use.