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FTC consumer review rule: what a local business may ask

Mir · · 6 min read

Topics: Reviews,Ftc,Google,Compliance

The FTC consumer review rule, in force since October 21, 2024, lets a local business ask every customer for a review, and even offer a reward for one, as long as the reward does not depend on what the review says. It prohibits fake reviews, reviews bought on condition of a good rating, undisclosed reviews the business asked its own staff for, and threats or false accusations aimed at a reviewer. Google's own policy is stricter than the FTC on two points: it bans any incentive for a review, and it bans asking only the customers you expect to be happy. A business that sends the same plain request to everyone, offers nothing for it, and answers every review is inside both. The FTC moved from warning letters in December 2025 to lawsuits in 2026, including a May case over thousands of fake listings for home repair companies.

In short

  • The FTC says civil penalties under the rule can reach $53,088 per violation.
  • 97% of consumers read reviews for local businesses, and 97% think businesses should be punished for fake ones (BrightLocal, 2026).
  • The FTC sent warning letters to 10 companies on December 22, 2025, and with Illinois sued a home repair lead company on May 11, 2026.
  • 81% of consumers expect a reply to their review within a week (BrightLocal, 2026).
A florist in a green apron smiles while on a phone call and writes in a notebook beside vases of flowers
A review request is a few words, and the rule turns on which words. Photo: Amina Filkins, Pexels.

What the FTC consumer review rule allows and prohibits

The FTC's question-and-answer guidance sets out the lines a small business meets most often. Google's Maps policy governs what may be posted on a business listing and is separate from the law. The two do not draw every line in the same place.

What the business doesFTC ruleGoogle Maps policy
Writes or posts reviews itselfProhibitedProhibited
Offers a reward only for a five-star reviewProhibitedProhibited
Offers a reward for any review, good or badAllowedProhibited
Asks only customers it expects to be happyNot in the rule; "could violate the FTC Act"Prohibited
Discourages or blocks negative reviewsProhibited when done by intimidation or false accusationProhibited
Asks staff to collect a set number of reviewsNot addressed in the FTC guidanceProhibited

On incentives, the FTC's wording is direct: the rule "does not prohibit giving incentives for reviews, as long as there isn't an express or implied requirement that the reviews have to express a particular sentiment." Its example of an implied requirement is an offer to "tell us how much you loved your visit" in exchange for a coupon.

On employees, a business may ask its own staff for reviews only with a "clear and conspicuous" disclosure of the relationship. A general request sent to all purchasers does not need that disclosure, even if an employee happens to be one of them.

On suppression, the rule covers false accusations about a reviewer and intimidation, which the FTC defines as "abusive communications, stalking, character assassination, and sexual harassment." Sorting reviews by rating or helpfulness is not suppression.

Why the old habits now carry risk

A tradesman in grey overalls with a clipboard talks with a homeowner who holds a small box beside open wall shelving
A request sent after the job is where the wording matters. Photo: Pavel Danilyuk, Pexels.

Three habits still turn up in local service marketing: a discount on the next visit for a five-star review, a text that goes only to customers the technician marked as happy, and asking the office staff to post a few reviews to get the count up. The first is prohibited by the rule. The second is prohibited by Google and, in the FTC's words, could violate the FTC Act. The third needs a disclosure under the rule, and Google's policy separately prohibits asking staff to solicit a set number of reviews.

Enforcement has started. On December 22, 2025 the FTC sent warning letters to 10 companies and said penalties "can quickly add up." On May 11, 2026 the Department of Justice, acting on notification from the FTC, and the Illinois Attorney General sued Premium Home Service, a Chicago company the FTC says created thousands of fake online listings for nonexistent home repair businesses, with local addresses and local area codes, and posted fabricated five-star reviews for them. The complaint alleges calls were routed to representatives in the Philippines and unqualified technicians were sent to homes. According to DLA Piper, the defendants moved to dismiss on July 17, 2026, and the case is pending.

How to ask for reviews under the rule

A technician in blue overalls stands on a stepladder and crimps the end of a white cable
The request should go out because the job closed, not because the technician thought it went well. Photo: Audy of Course, Pexels.
  1. Send the request to every customer after every completed job. Trigger it from the job or invoice record, not from a technician's judgement. That removes the selective-solicitation question entirely.
  2. Word it neutrally. "How did we do? You can leave a review here" is fine. "Loved your service? Tell everyone" implies the sentiment you want.
  3. Offer nothing for a Google review. The FTC allows a sentiment-neutral reward, but Google's policy prohibits discounts, payment or free services "in exchange for posting any review." Most local businesses care most about the Google listing, so the simplest rule is no reward.
  4. Keep staff out of it, or disclose. Do not ask employees, relatives or friends to review the business. If you ask an employee for a review anywhere, the FTC requires a clear and conspicuous disclosure of the relationship.
  5. Give unhappy customers a way to reach you, without taking away the public link. A reply to the owner can sit alongside the review link. It cannot replace it.
  6. Reply to every review, and never threaten or accuse a reviewer. BrightLocal's 2026 survey found 19% of consumers expect a reply the same day and 81% within a week. A calm reply to a bad review is allowed; a message falsely accusing the reviewer can be the suppression the rule prohibits.

The mistake most businesses make at step 5

They route the unhappy customer to a private form instead of the review site. That is review gating under another name: the customers most likely to post a negative review never see the public link. Send everyone the same link first. If the customer says something went wrong, open a conversation with the owner as well. The customer can still post whatever they want.

What we build for this

Our online reputation management work runs exactly that sequence: the request fires from the software a business already uses, every customer gets the public link, unhappy answers also reach the owner, and replies are drafted in the business's voice. We do not buy, write or filter reviews, and we do not remove honest criticism. Review requests sent by text are also text messages, so the consent and opt-out rules in TCPA revocation of consent are worth reading alongside this. More of what we build for local businesses is on the services page. This post explains the rule and the policy; it is not legal advice.

Sources

  1. Federal Trade Commission, The Consumer Reviews and Testimonials Rule: Questions and Answers (2024)
  2. Federal Trade Commission, A warning letter (or ten) for businesses: comply with the FTC's Consumer Review Rule (2025)
  3. Federal Trade Commission, FTC and Illinois Take Action to Stop Deceptive Conduct by Company that Created Thousands of Business Listings of Fake Local Home Repair Businesses (2026)
  4. DLA Piper, FTC's 2026 enforcement approach to fake reviews takes shape: Takeaways for companies (2026)
  5. Google, Maps user-generated content policy: prohibited and restricted content (2026)
  6. BrightLocal, Local Consumer Review Survey 2026 (2026)

Questions people ask

What does the FTC consumer review rule prohibit?

The FTC's Rule on the Use of Consumer Reviews and Testimonials, in effect since October 21, 2024, prohibits fake reviews, paying or giving incentives for reviews that must express a particular sentiment, undisclosed reviews from insiders when a business asks for them specifically, and review suppression through false accusations about a reviewer or intimidation. The FTC says courts can impose civil penalties for knowing violations.

Can a business offer a discount for leaving a review?

Under the FTC rule, yes, if there is no express or implied requirement that the review be positive. The FTC's own example of an improper offer is one that asks the customer to say how much they loved their visit in exchange for a coupon. Google's Maps policy is stricter: it prohibits offering incentives such as payment, discounts or free goods or services in exchange for posting any review, so a business that wants reviews on its Google listing should offer nothing.

Is review gating illegal?

The FTC review rule does not contain a specific prohibition on asking only satisfied customers for reviews, but the FTC says the practice could violate the FTC Act and points to its Endorsement Guides. Google's policy separately prohibits businesses from selectively soliciting positive reviews or discouraging negative ones. The safe practice is to send the same request to every customer.

What is the penalty for fake reviews?

The FTC said in December 2025 that civil penalties under the rule can reach up to $53,088 per violation. In one 2026 case, TruHeight, which the FTC alleged had used employee-written reviews and incentives for five-star reviews, the order carried a $4 million judgment, partially suspended on payment of $750,000, according to DLA Piper.

Mir, Founder, Analytica Solutions

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