Key takeaways:
- The FTC fake reviews rule, 16 CFR Part 465, took effect on October 21, 2024, and covers Google reviews.
- Knowing violations can cost up to $53,088 per violation, a 2025 figure the FTC kept unchanged for 2026.
- Asking every customer for a review stays legal; paying or rewarding only positive reviews does not.
- Google goes further than the FTC and bans any incentive for a review, even one without conditions.
- In December 2025, the FTC warned 10 companies about fake reviews and incentives for five-star reviews.
Table of contents
The FTC fake reviews rule is a federal regulation, 16 CFR Part 465, that bans fake reviews, sentiment-conditioned incentives, undisclosed insider reviews and review suppression, with civil penalties for businesses that knowingly break it. Its official name is the Trade Regulation Rule on the Use of Consumer Reviews and Testimonials, and the Federal Trade Commission (FTC) finalized it on August 14, 2024. For a local business, the rule is concrete. It applies to the ratings on your Google Business Profile and Google Maps listing, whether you ask by email, with a QR code or with an NFC card that customers tap with an iPhone or Android phone. In May 2026, the FTC and the Illinois attorney general sued a company accused of posting fabricated five-star reviews on thousands of fake local listings. This guide explains what the rule prohibits, what stays allowed, where Google is stricter, what a violation costs, and how to comply.
What is the FTC fake reviews rule?
The FTC fake reviews rule is the Trade Regulation Rule on the Use of Consumer Reviews and Testimonials, codified at 16 CFR Part 465. The Federal Trade Commission voted 5-0 to adopt it on August 14, 2024, and the final rule took effect on October 21, 2024. FTC staff now call it the Consumer Review Rule.
The rulemaking began with an advance notice in November 2022, followed by a proposed rule in July 2023. The final rule banning fake reviews was published in the Federal Register on August 22, 2024 (89 FR 68034). Its main novelty is the remedy: under Section 5 of the FTC Act alone, the agency generally needs a prior order or a trade regulation rule to seek civil penalties. Part 465 is that rule for reviews and testimonials.
16 CFR 465.1 defines a consumer review as a consumer's evaluation, or a purported consumer's evaluation, of a product, service, or business that is submitted by the consumer or purported consumer and that is published to a website or platform dedicated in whole or in part to receiving and displaying such evaluations.
That definition covers a Google rating, a star score on Google Maps and the widget on your own website. Testimonials in your advertising and marketing, from a celebrity testimonial to a quote from a happy client on a flyer, are covered too.
A "business" under the rule is any individual or entity that sells products or services, with no size threshold, so a solo plumber is held to the same standard as a national retailer. The rule works alongside the FTC's Endorsement Guides, which the FTC says "address a broader range of conduct than the rule," such as payments to an influencer.
| Date | Milestone | Source |
|---|---|---|
| July 31, 2023 | Proposed rule published | Federal Register |
| Aug. 14, 2024 | FTC votes 5-0 to finalize the rule | FTC press release |
| Oct. 21, 2024 | Rule takes effect | Federal Register |
| Dec. 22, 2025 | Warning letters to 10 companies | FTC press release |
| May 11, 2026 | FTC and Illinois sue Premium Home Service | FTC press release |
In practice, compliance for a shop, salon or clinic comes down to how you ask. A request made the same way to every customer, with no reward tied to the rating, is what the rule leaves untouched, whether it goes out by email or through review cards for your counter.
What practices are prohibited by the FTC?
The final rule prohibits businesses from six practices: fake or false consumer reviews and testimonials, incentives conditioned on sentiment, undisclosed reviews by company insiders, company-controlled review websites, review suppression, and the misuse of fake social media indicators.
A seventh section, on review hijacking, was dropped before the final vote, so section 465.3 is reserved. Each violation is treated as an unfair or deceptive trade practice. The table maps each prohibition to a situation a local business could face.
| Practice | Section | Local example |
|---|---|---|
| Fake testimonials | 465.2 | Owner posts five-star ratings under invented names |
| Buying by sentiment | 465.4 | 10% off in exchange for a five-star rating |
| Insider reviews | 465.5 | Manager rates the store without disclosing the role |
| Controlled sites | 465.6 | A "best dentists in town" site you secretly own |
| Suppression | 465.7 | Groundless lawsuit threat against a critic |
| Fake influence | 465.8 | Buying bot followers for a business account |
Fake or false consumer reviews and testimonials (465.2)
Section 465.2 targets misrepresenting consumer experiences. A business may not write, create or sell a review or testimonial that misrepresents that the reviewer exists, used the product, or what the person experienced. It also may not purchase such a review or procure one from officers, managers, employees or agents or their relatives. A business is liable when it knew or should have known.
Paying a vendor for Google ratings adds federal exposure to the platform risk, covered in our guide to the risks of buying reviews.
Buying positive or negative reviews (465.4)
Section 465.4 is the provision most likely to catch an ordinary business. It does not prohibit rewards for reviews; it prohibits rewards tied to what the review says, and the condition can be implied. A coupon "for your five-star review" is the textbook case.
Paying for one-star ratings about a rival is covered too, since the text names both sentiments. It applies on your own website and on any online platform such as Google.
It is an unfair or deceptive act or practice and a violation of this part for a business to provide compensation or other incentives in exchange for, or conditioned expressly or by implication on, the writing or creation of consumer reviews expressing a particular sentiment, whether positive or negative, regarding the product, service, or business that is the subject of the review.
16 CFR 465.4, Electronic Code of Federal RegulationsCompany insiders and review websites (465.5 and 465.6)
An officer or manager may post a consumer review of the business only with a clear and conspicuous disclosure of the relationship. A business may not use a testimonial from an employee when the testimonialist's tie is unclear to the audience. Managers who ask staff or relatives for reviews must instruct them to disclose it. Generalized solicitations to all purchasers, and merely engaging in review hosting, are exempt. A business also may not present a site it controls as a source of independent opinions about its own category.
Review suppression and fake social media indicators (465.7 and 465.8)
Review suppression covers groundless legal threats, physical threats, intimidation and knowingly false public accusations used to stop or remove a review. It also covers a review page that hides negative ratings while implying it shows them all. Replying firmly to a bad review is fine. Section 465.8 bans selling or buying fake followers, likes or views that inflate an influencer's or a brand's reach for a commercial purpose.
What is still allowed when you ask for reviews?
Asking for reviews is still allowed under the FTC rule, as long as the request does not dictate a sentiment. A business can ask every customer, send a reminder and even offer a thank-you, but Google's review policy is stricter than federal law on that last point.
The FTC's guidance gives the example of a company that emails all recent customers, a few of whom are employees: that generalized solicitation does not violate the insider section. Honest feedback from real people, asked for evenly, is the model.
Review gating, asking only customers you believe are happy, sits in a gray zone. The FTC says the rule "does not contain a specific prohibition against such conduct" but that the practice "could violate the FTC Act." Filtering who gets the review link is a risk, not a loophole.
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. But remember that failing to disclose incentives could be a violation of the FTC Act.
Federal Trade Commission, The Consumer Reviews and Testimonials Rule: Questions and AnswersWhere Google's policy is stricter
Google's Maps User Contributed Content Policy treats as fake engagement any incentive, such as payment, discounts or free goods and services, in exchange for posting any review. A raffle offered to every reviewer, legal under 16 CFR 465.4 with a disclosure, still breaks Google's rules.
The same policy bans selectively soliciting positive reviews and says merchants should not require or pressure users to leave ratings while on the premises. Google says violations can lead to actions ranging from suspended account privileges to termination.
Incentives allowed if disclosed and tied to no sentiment. Gating absent from the rule, but risky under the FTC Act.
No incentive of any kind. No selective solicitation, no pressure on the premises.
The practical conclusion: follow the stricter text. A neutral request, with no reward, satisfies both the FTC and Google.
A Digifeel NFC card or plate opens the Google review page by tap or QR code, on iPhone and Android, without filtering who reviews or what they write. Wording and timing then matter most, and these tips on asking customers for reviews stay within both sets of rules.
One tap or one QR scan opens your Google review page. No reward, no filtering, no subscription: the same neutral request for every customer, on iPhone and Android, set up in a few minutes.
See the review cards →
What are the penalties for fake reviews?
The penalty for fake reviews under the FTC rule is a civil penalty of up to $53,088 per violation, the maximum penalty set by the 2025 inflation adjustment. A court sets the final amount for knowing violations, and the cap applies to each violation, not to each case.
The figure did not move in 2026. In a Federal Register notice effective September 15, 2026, the FTC said that, following guidance from the Office of Management and Budget, it would keep applying the 2025 levels.
$53,088 per violation is the maximum civil penalty since January 17, 2025, up from $51,744, according to the FTC's 2025 civil penalty adjustment.
Penalties for violations go beyond fines. FTC orders can also require monetary payments: in the TruHeight case, the settlement included a $4 million judgment, partially suspended, with $750,000 to be paid. A state government can join the case, as Illinois did.
Is it illegal to have fake reviews on your profile?
Fake reviews are illegal for the business that writes, sells, buys or knowingly disseminates them. A fake rating a stranger posts on your Google Business Profile without your involvement is outside your liability under Part 465. Flag it to Google and keep a record.
How does the FTC enforce the rule?
The FTC enforces the fake reviews rule through warning letters, federal lawsuits that seek civil penalties, and settlements, sometimes alongside state attorneys general. Enforcement actions moved from warnings in late 2025 to complaints citing the rule in April and May 2026.
The December 2025 warning letters
On December 22, 2025, the FTC warned 10 companies about possible violations of the Consumer Review Rule, based on consumer complaints. The letters cited civil penalties of up to $53,088 per violation.
The FTC did not name the recipients. A July 2026 DLA Piper analysis, based on public records, lists six property management companies, three personal injury law firms and one accounting firm. The recipients were local service firms, not global brands.
The 2026 lawsuits
On April 13, 2026, the FTC announced a case against TruHeight, a supplement seller, alleging that several thousand five-star reviews were written by employees and that buyers got free or discounted products for five-star reviews.
On May 11, 2026, the FTC and the Illinois attorney general sued Premium Home Service over thousands of fake home repair listings boosted by fabricated five-star reviews, seeking civil penalties under the rule. Christopher Mufarrige, Director of the FTC's Bureau of Consumer Protection, said the company's "use of fake business profiles and reviews violates federal and state laws, harming consumers and businesses."
What the 2026 cases have in common Both paired fake reviews with rewards for five-star ratings, the exact combination of sections 465.2 and 465.4.
How to comply with the FTC's rule: a checklist for local businesses
Complying with the FTC's rule, for a local business, means checking four things: who writes your reviews, how you ask for them, what you give in return, and how you respond to criticism. These compliance tips follow the order most small teams meet them.
- Delete any review you or your staff wrote under a false identity.
- Stop paying any vendor that sells reviews, followers or ratings.
- Remove every reward tied to a star rating, including "leave us 5 stars."
- For Google, drop incentives entirely, even raffles open to every reviewer.
- Send the same request to every customer in your customer data, not only to happy ones.
- Tell managers not to rate the business, and ensure employees include a disclosure if they post.
- Replace legal threats with a factual public reply.
- If your site shows reviews, apply one moderation rule to every rating.
Keep a written record of your process: script, channel and start date. A documented, neutral process is your best evidence of good faith.
Third parties can also post fake reviews on your profile, so learn to spot suspicious review patterns; a sudden burst of five-star ratings is one of the red flags.
- Do: ask every customer at the same point, in person, by email or with a QR code.
- Do: answer negative reviews with facts and an offer to fix the problem.
- Don't: offer a discount, gift or raffle entry for a Google review.
- Don't: send the review link only to customers who rated you well in a survey.
These steps cost no money and remove the practices named in the 2026 complaints.
If a program sits in a gray zone, such as a loyalty scheme that mentions reviews, pause it until someone qualified checks it.
This guide summarizes public FTC, Federal Register and Google documents for general information. For a specific program or dispute, consult a lawyer who handles consumer protection law.
FAQ
How can consumers report fake reviews?
People can report fake reviews to the Federal Trade Commission at ReportFraud.ftc.gov, the agency's fraud reporting portal, which feeds its investigations. On Google Maps, anyone can also flag a review from the review itself. Reporting to both helps: Google can remove the content, while the FTC can pursue the business behind it.
Does the rule cover reviews written with artificial intelligence?
Yes. Announcing the final rule, the FTC cited "AI-generated fake reviews" as an example of reviews that misrepresent that they are by someone who does not exist. A business that uses artificial intelligence to produce reviews from customers who never bought anything is creating fake reviews under section 465.2.
Can my employees leave Google reviews for our business?
Under the FTC rule, officers and managers may not post undisclosed reviews, and managers who ask staff for reviews must tell them to disclose the relationship. Google goes further: its policy treats content based on a conflict of interest, including current or former employment, as a violation. Employees are safest staying out of it.
Can I ask a customer to change or remove a negative review?
You can reply publicly, fix the problem and let the customer decide whether to update the review. The FTC rule bans groundless legal threats, intimidation or false accusations used to get it removed. Google's policy also bans offering discounts or free services in exchange for revising or removing a negative review.
Where to start this week
The FTC fake reviews rule changes little for a business that already asks every customer the same way and gives nothing for a rating. It changes a lot for one that pays for reviews, rewards five stars or lets managers post anonymously. Start with a 30-minute audit of your current review requests. Read your email templates, counter signs and staff scripts, and remove any reward, any mention of a star rating and any filter on who gets the link. Then write down the process you keep. Which of your current requests would you be comfortable showing to an FTC investigator?