THE FTC IS SENDING WARNING LETTERS ABOUT REVIEWS.
The FTC's rule on fake and incentivized reviews took effect in October 2024. In December 2025 the agency announced warning letters to 10 companies under it. If you ask customers for reviews, here is what the rule covers, and what FTC staff say is and isn't allowed.
AT A GLANCE
By Conqueror Capital · Published
The change: The FTC announced the warning letters December 22, 2025.1
WHAT CHANGED
On December 22, 2025, the FTC announced that its staff sent letters to 10 companies warning them of potential violations of the Consumer Review Rule.1 FTC staff guidance says the rule went into effect on October 21, 2024.3
The FTC says the letters were based on consumer complaints and information provided by the companies, and are not formal determinations that the recipients violated the rule. They warn that violations can lead to a federal lawsuit or other legal action, and civil penalties of up to $53,088 per violation.1 The FTC did not name the companies in its release.1
WHAT THE RULE PROHIBITS
- Fake experiences. Reviews and testimonials that misrepresent whether the reviewer's experience was positive or negative, or whether the reviewer used the product or service at all.1
- Rewards for a sentiment. Conditioning compensation or other incentives on a review being positive or negative.1
- Undisclosed insiders. Failing to disclose reviews written by company insiders or their immediate relatives.1
- More provisions on company-controlled review websites, suppressing certain reviews, and misusing indicators of social media influence such as follower or view counts.1
The FTC's business blog puts it plainly: companies using fake reviews or providing incentives for 5-star reviews misrepresent consumer experiences and may face enforcement and civil penalties.2
WHAT FTC STAFF SAY
FTC staff published answers to business questions. They note the guidance isn't definitive and isn't a safe harbor.3 Points that matter to a local business:
- Incentives aren't banned outright. The rule allows incentives for reviews as long as there is no express or implied requirement that the review express a particular sentiment, though failing to disclose incentives could violate the FTC Act.3
- Implied counts. Staff give examples such as "Tell us how much you loved your visit to John’s Steakhouse and get a $5 coupon" as implying the review must be positive.3
- Paying for 5-star reviews with a disclosure still violates the rule, on your own site or on third-party platforms.3
- Asking only happy customers isn't specifically prohibited by the rule, but staff say it could violate the FTC Act.3
- Agencies aren't immune. Advertising agencies and reputation management companies could be liable for writing or selling fake reviews or paying for reviews with a particular sentiment.3
WHO IT AFFECTS
Any business that asks for reviews, features testimonials in ads or on its website, or hires someone to manage its reputation. FTC staff say a business that puts testimonials on its own website is disseminating them, not merely hosting them.3
Google adds its own layer. Its Maps policy does not allow merchants to offer incentives for any review, or to discourage negative reviews or selectively solicit positive ones.4 That is stricter than the FTC rule on incentives, so a practice the rule permits can still break Google's policy.
QUICK QUESTIONS
Can a customer be fined for a fake review?
FTC staff say ordinary consumers can't be liable under the rule for what they say in reviews; the provisions on review content apply to businesses.3
Am I liable for fake reviews on my own website?
Not for reviews you merely host, according to FTC staff, as long as you didn't write or buy them. That exemption still applies if you ask customers for reviews or show star ratings, but not when you feature reviews in your advertising.3
Can a competitor sue me under the rule?
FTC staff say the rule does not provide a private right of action.3
WHAT TO DO
- Ask every customer the same way. A neutral request, sent to everyone, with no reward attached. Our guide on getting more Google reviews walks through it.
- Remove review gates. If your system only sends happy customers to Google, turn that off.4
- Check who wrote your reviews. Staff and family reviews need a disclosure under the rule;1 Google's policy treats employment and family ties as a conflict of interest.4
- Audit your testimonials on your site and in ads. Each should reflect a real customer's real experience.3
- Ask your agency how reviews are gathered. See reputation management beyond Google for the other platforms to check.
SOURCES
- Federal Trade Commission, FTC Warns 10 Companies About Possible Violations of the Agency’s New Consumer Review Rule, December 22, 2025.
- FTC Business Blog, A warning letter (or ten) for businesses: comply with the FTC’s Consumer Review Rule, December 22, 2025.
- FTC Business Guidance, Consumer Reviews and Testimonials Rule: Questions and Answers.
- Google Maps Help, Prohibited & restricted content (Maps user-generated content policy).
Platforms change often. Check the sources for the current version before acting.
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