The FTC Already Wrote Down What a "Business Coaching Opportunity" Is. The Number Attached Is $53,088 a Violation.
A rulemaking that has been sitting in the FTC's pipeline since January 2025 would turn every client-income screenshot into a paperwork obligation.
Start with the sentence, because the sentence is the whole story.The FTC's proposed amendments define "business coaching opportunities" broadly to include any program, plan, or product that is represented to train or teach a person how to establish or operate a business.
Read that twice if you sell a program that helps people start consulting, freelancing, agency work, e-commerce, or any other version of working for themselves.
What was actually proposed
On January 13, 2025, the Federal Trade Commission announced it was seeking public comment on proposed changes to the Business Opportunity Rule and a proposed new Earnings Claim Rule. The first proposal would expand the Business Opportunity Rule to cover other money-making opportunities, such as business coaching and investment opportunities, and would re-title the rule the "Business and Money-Making Opportunity Rule." As proposed, the amendments wouldn't cover franchises or MLMs.
The agency also floated going further. The Commission considered using the term "coaching opportunity" instead of "business coaching opportunity," defined more broadly to include any program represented, expressly or by implication, to train or teach a person how to generate or increase earnings.
That version would reach mindset coaches, sales coaches and career coaches who have never once used the word "business opportunity" about themselves.
The paperwork part
Here is the operational detail coaches should sit with. Sellers would be required to have written substantiation to back up any earnings claims and make that substantiation available to consumers if they request it, in the language they used to make the earnings claim.
In the language you made the claim in. Run Spanish-language ads, keep Spanish-language proof.
The existing rule already gives a preview of what "proof" means in FTC terms. A covered seller's earnings claim statement must carry the heading "EARNINGS CLAIM STATEMENT REQUIRED BY LAW" and give, among other things, the dates the earnings were achieved and the number and percentage of all purchasers up to that date who earned at least the stated amount.
Number and percentage. Not your best client.
Where the number comes from
The FTC can seek civil penalties of up to $53,088 for each violation of a trade regulation rule or final order, and every day a violation continues counts as its own offense. That maximum is unchanged for 2026. Deceptive earnings claims are already illegal; the proposed changes would let the FTC seek stronger relief, including money back for consumers and civil penalties.
Nothing is final
The Commission approved the proposals 3-2, with Commissioners Andrew Ferguson and Melissa Holyoak voting no, and Ferguson issuing a dissent joined by Holyoak. Ferguson, now chairman, wrote that the outgoing Commission's window for new rules had "ended the morning after the presidential election." There is no final FTC earnings claim rule.
But the proposals have not been withdrawn either. Both were still active on the FTC's agenda as of mid-2026, one of them covering business coaching, investment education and online courses.
Meanwhile the agency keeps talking about this category publicly. The FTC says business owners and consumers should be cautious of coaching programs that promise guaranteed income, quick money or "proven" systems with little risk. Its own advice tells buyers to read success stories and testimonials with skepticism, because glowing stories could be fake or misleading.
The cheap version of compliance
None of this requires a lawyer yet. It requires a spreadsheet.
For every earnings claim you currently have live — sales page, ad, webinar replay, carousel, podcast intro — log the client, the dated evidence, how many people bought that program, and how many hit that result. If you can't fill the last two columns, you don't have substantiation. You have an anecdote.
The rule may never land. The spreadsheet is useful regardless.
Sources
- FTC Proposes Rule Changes and New Rule to Deter Deceptive Earnings Claims by Multilevel Marketers and Money-Making Opportunity Sellers — Federal Trade Commission
- Business Opportunity Rule: Notice of Proposed Rulemaking — Federal Trade Commission
- Concerned about deceptive earnings claims? So's the FTC, and we want your feedback — FTC Business Guidance Blog
- FTC Puts Pedal to the Metal to Release Proposed Rule on MLM Earnings Claims, Changes to Business Opportunity Rule — Kelley Drye Ad Law Access
- FTC Issues Proposed Rulemakings Related to Deceptive Earnings Claims — All About Advertising Law (Venable)
- FTC Proposes Changes to Deter Deceptive Earnings Claims by Multilevel Marketers and Money-Making Opportunity Sellers — The Franchise Memorandum
- FTC Civil Penalties: Caps, Court Process, and Deadlines — FedLaws
- Adjustments to Civil Penalty Amounts — Federal Register
- How to spot and avoid business coaching scams — FTC Consumer Advice
- Business Coaching or Business Scam? FTC Shares Red Flags — ACA International
- The FTC Wants to Rewrite the Rules for Anyone Selling Advice Online — The Useful Daily
- Business Opportunity Rule and earnings claim rule status — MMOL Database
- FTC Business Opportunity Rule: The 7-Day Payment Wait — PayKings
Editor’s note: Half the industry markets with client income screenshots and almost none of them keep the denominator. The proposed rule puts a dollar figure on that gap.
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