The compliant review playbook

Most small businesses breaking the FTC review rule have no idea they are doing it. The two most common violations are things marketers have recommended for years.

The number that gets attention is the penalty. The number that should get attention is per violation. This is not a single fine for a bad practice, it is a per-item exposure, which is what makes a batch of purchased reviews genuinely dangerous rather than merely embarrassing.

What the rule prohibits

1. Fake and purchased reviews

   Reviews by people who do not exist, or who never used the product or service. Buying them, selling them, or knowingly displaying them.

   This includes AI-generated reviews presented as real customer experiences.

2. Undisclosed insider reviews

   Reviews written by owners, employees, family members or contractors without clearly disclosing the relationship.

   Asking your staff to review the business is the single most common accidental violation. If they do it, the connection has to be disclosed in the review itself.

3. Review gating

   Suppressing negative reviews by only inviting people you expect to be positive. The classic version is a survey that routes happy customers to the review link and unhappy ones to a private feedback form.

   This was standard advice in reputation-management software for a decade. It is now specifically prohibited.

4. Buying influence indicators

   Purchasing followers, views or engagement to misrepresent influence, where it matters materially to customers.

5. Suppressing reviews with threats

   Using unfounded legal threats, physical threats or intimidation to force a review down.

What is still completely fine

• Asking every customer for a review. Encouraged, and the highest-return thing you can do.
• Reminding them once if they do not respond.
• Offering an incentive for a review as long as it is not conditioned on the review being positive, and the incentive is disclosed. The safer path for a small business is simply not to incentivise at all.
• Replying to reviews, including disputing the facts politely.
• Reporting reviews that break a platform’s own policies.
• Displaying selected genuine reviews on your own website, as long as you are not systematically hiding the negative ones to create a false impression.
• Asking an unhappy customer to contact you directly, provided you still send them the review link like everyone else.

The five-minute self-audit

Answer these honestly

• Does anything in our review process decide who gets the review link based on how happy they seem? If yes, that is gating. Remove the branch.
• Have any staff, family members or contractors left us a review without disclosing the relationship? If yes, ask them to disclose it or remove it.
• Have we ever paid for reviews, including through an agency or a marketplace seller? If yes, stop, and take advice about what is already published.
• Does our review software have a "filter negative feedback" or "private feedback first" feature switched on? That is gating with a friendly name.
• Do we display testimonials on our site chosen so as to hide a pattern of complaints?
• Have we ever threatened a reviewer with legal action?

The compliant process, in one line

Ask every customer, at the same point in the job, with the same words, and send everyone the same link. If your process survives that sentence unchanged, you are almost certainly fine. If it needs an exception, that exception is probably the violation.