Most Advice About the FTC Review Rule Is Wrong in Both Directions

Six Practices, and the Sixth Catches People Off Guard

The rule addresses fake or false reviews including AI-generated ones, incentives conditioned on a particular sentiment, undisclosed insider reviews, misrepresenting a controlled site as independent, suppression by threats or false accusations, and the buying or selling of fake indicators of social media influence such as bot followers (Federal Trade Commission, 2024).

Start with the actual list, because most coverage paraphrases it into something vaguer than it is.

The Commission describes a final rule addressing reviews and testimonials that misrepresent they are by someone who does not exist, such as AI-generated fake reviews, or by someone without actual experience with the business. It prohibits providing compensation or other incentives conditioned on the writing of consumer reviews expressing a particular sentiment, either positive or negative. It prohibits certain reviews and testimonials written by company insiders that fail to clearly and conspicuously disclose the giver’s material connection to the business. It prohibits a business from misrepresenting that a website or entity it controls provides independent reviews or opinions. It prohibits using unfounded or groundless legal threats, physical threats, intimidation, or certain false public accusations to prevent or remove a negative consumer review. And it prohibits anyone from selling or buying fake indicators of social media influence, such as followers or views generated by a bot (Federal Trade Commission, 2024).

The sixth one is the surprise for most local businesses, because it has nothing to do with reviews. If somebody sold you social growth at some point, and the followers arrived from a service rather than from people, that transaction is inside the scope of this rule. It is worth knowing what was bought on your behalf.

The rule went into effect on October 21, 2024, and it authorizes courts to impose civil penalties for knowing violations (FTC Business Guidance, 2026). That last clause is the reason this stopped being a platform policy question. A review that breaches Google’s terms gets removed. A practice that breaches a federal rule is a different category of problem.

One thing to be plain about before the detail. This page describes a published federal rule. It is not legal advice, the rule is enforced by the Commission and interpreted by courts, and anything that matters to your business should go to your own counsel.

Asking Only Your Happy Customers: the Honest Answer

On whether a business may seek reviews only from customers it believes are satisfied, the FTC answers that the rule does not contain a specific prohibition against such conduct, but that this practice could violate the FTC Act (FTC Business Guidance, 2026). Neither a green light nor a ban, which is why both common summaries are wrong.

This is the single most argued-about question in local marketing, and the FTC answers it directly.

Asked whether a business can ask for reviews only from customers it thinks are happy, the Commission states that the rule does not contain a specific prohibition against such conduct, and adds that this practice could violate the FTC Act (FTC Business Guidance, 2026).

Read both halves, because almost every article on this subject drops one of them. It is not prohibited by this rule. It could still be unlawful under the broader Act. An agency telling you gating is banned outright is overstating the rule, and an agency telling you it is fine because the rule does not mention it is ignoring the second sentence.

The practical conclusion is not really a legal one. Filtering who you ask means your public record describes a curated subset of your customers rather than your customers, which is a weaker asset even setting the rule aside. A business that asks everybody gets a rating that is defensible, a flow of feedback that is actually operationally useful, and an occasional critical review that, handled well, does more for trust than a wall of uniform praise. That argument is made in full in our piece on how review volume moves local rankings.

So the recommendation is to ask every customer, on a consistent cadence, without screening for expected sentiment. That is both the safer position and the better-performing one, which is a rare combination.

Incentives Are Not Banned, Sentiment Conditions Are

The FTC states that the rule does not prohibit giving incentives for reviews, as long as there is not an express or implied requirement that the reviews express a particular sentiment (FTC Business Guidance, 2026). The line is not the incentive, it is the condition attached to it.

Here is where the popular advice is most confidently wrong.

The Commission states that the rule does not prohibit giving incentives for reviews, as long as there is not an express or implied requirement that the reviews have to express a particular sentiment (FTC Business Guidance, 2026). The prohibition in the rule attaches to compensation or incentives conditioned on a review expressing a particular sentiment, positive or negative (Federal Trade Commission, 2024).

So the distinction is between paying for a review and paying for a good review. A prize draw open to anyone who leaves a review of any kind sits differently from an offer that arrives with, or clearly implies, an expectation of five stars. And implied matters as much as express, which means the wording of the request does real work.

That has a practical consequence worth acting on. Go and read your own review request, the one your booking system or your invoice software sends automatically, and read it as a stranger would. If it mentions the incentive and the desired rating in the same breath, or leans on language about helping us keep our five star rating, it is carrying an implication whether or not anybody intended one.

The same goes for whatever your team says at the counter. The written template is easy to audit. The verbal version is the one that quietly drifts.

Suppression Means Threats, Not Housekeeping

The prohibited conduct is using unfounded or groundless legal threats, physical threats, intimidation, or certain false public accusations to prevent or remove a negative review (Federal Trade Commission, 2024). The FTC separately states that organizing reviews is not suppressing reviews under the rule (FTC Business Guidance, 2026).

Suppression sounds like the broadest term in the rule and is actually one of the narrower ones.

What the rule reaches is the use of unfounded or groundless legal threats, physical threats, intimidation, or certain false public accusations, in order to prevent a negative consumer review from being written or to get one removed (Federal Trade Commission, 2024). That is conduct aimed at a person, not a display preference.

And the Commission addresses the display question directly, stating that organizing reviews is not suppressing reviews under the rule, while noting that arranging reviews so as to obscure negative feedback could be an unfair or deceptive act or practice in violation of Section 5 of the FTC Act (FTC Business Guidance, 2026). Sorting is not suppression. Sorting designed to hide is a different argument under a different provision.

The behavior most likely to catch an ordinary local business here is the angry response to an unfair review. A demand letter over a review that is merely unflattering, or a public accusation that the reviewer is a competitor when you have no basis for saying so, is closer to the conduct described than most owners realize in the moment. The measured alternative, including what genuinely does qualify a review for removal, is covered in handling competitor and negative reviews.

Reporting a review to the platform under its own policies is a normal, legitimate step and is not what this provision is about. The difference is between using a published process and applying pressure to a person.

Insider Reviews Are the Most Common Local Violation

The rule prohibits certain reviews and testimonials by company insiders that fail to clearly and conspicuously disclose the giver’s material connection to the business (Federal Trade Commission, 2024). In a small business the insiders are the staff, the family and the friends who were asked to help early on.

Of the six practices, this is the one most likely to already exist on a local business profile, and usually nobody set out to break a rule.

The rule addresses reviews and testimonials written by company insiders where the material connection to the business is not clearly and conspicuously disclosed (Federal Trade Commission, 2024). For a national brand that means employees and agencies. For a five-person contractor in Collier County it means the owner’s brother-in-law, two staff, and the friend who was asked for a review in the first month because the profile looked empty.

Nobody remembers doing it and the reviews are still there. That is worth an honest hour: look at your oldest reviews, work out which came from people connected to the business, and deal with what you find rather than hoping the question never arises.

It also changes how you brief a team. Staff asking customers for reviews is ordinary and fine. Staff writing them is not, and the difference needs saying out loud, because to a well-meaning employee helping out looks like the same thing.

The broader principle is the one running through everything we publish about credentials and disclosure: a claim that cannot survive somebody checking it is a liability rather than an asset, which is the same argument as what Florida requires your website to say.

What to Change This Week

Read your own review request as a stranger would, audit your oldest reviews for insider connections, find out what any social growth service actually delivered, and stop screening who you ask. None of it takes long and all of it is checkable.

A short and genuinely finite list, because this is not a project.

First, read the review request your systems send automatically. Check that no incentive is tied, expressly or by implication, to a particular rating, and that the language does not lean on keeping a score up.

Second, audit the oldest reviews on your profiles for people connected to the business. You are looking for undisclosed material connections rather than for reviews you dislike.

Third, find out what any social growth or engagement service you have paid for actually delivered, since buying fake indicators of social media influence is inside the rule (Federal Trade Commission, 2024). If nobody can tell you where the followers came from, that is your answer.

Fourth, stop screening who gets asked. Ask everyone, on a schedule, and let the record be the record.

Fifth, decide in advance how you respond to a review you believe is false, so the decision is not made while angry. Use the platform’s reporting process, keep the public reply factual, and take anything genuinely defamatory to a lawyer rather than to the review thread.

Then leave it alone. This is a rule to comply with, not a strategy, and the actual work of earning reviews is unchanged by it. If you would like the rest of your visibility measured while you are at it, our free audit reports what is reachable and readable on your domain and costs nothing.