Should you pay for reviews? What the FTC rule says in plain English

Every contractor gets the pitch sooner or later: a batch of five star reviews for a flat fee, or a “reputation package” that promises a review a day. Others never buy anything but wonder whether a small gift card for every customer who posts a review is fine. The answer depends on which rulebook you read. The Federal Trade Commission’s rule on consumer reviews is federal law. Google’s content policy is a platform rule. They overlap, but not completely, and the gap is exactly where most honest contractors get confused.

The short answer

Sources for each line are in the sections below. On replies, Google says it reviews them to make sure “they follow Google’s content policies” (Google).

The rule in two dates and one number

The FTC’s Rule on the Use of Consumer Reviews and Testimonials “went into effect on October 21, 2024” (FTC). It sits in the Code of Federal Regulations as 16 CFR Part 465 (eCFR). The point of making it a rule, the FTC said when it announced it, was to “allow the agency to seek civil penalties against knowing violators” (FTC).

The second date is December 22, 2025. That day FTC staff sent warning letters to 10 companies and reminded them that rule violations can lead to “civil penalties of up to $53,088 per violation” (FTC). The same $53,088 figure is the current maximum in the FTC’s penalty table at 16 CFR 1.98 (eCFR). The FTC’s template letter gives, as an example of the conduct it targets, paying employees to obtain five star reviews from friends and family (FTC).

Two limits worth knowing: the letters are “not formal determinations” of a violation, and the rule “does not provide a private right of action”, so customers and competitors cannot sue you under the rule itself (FTC).

The rule section by section

Fake reviews (Section 465.2)

A business may not write, create or sell a review that misrepresents that the reviewer exists, that they actually used the business, or what their experience was. It also may not buy such a review when it “knew or should have known” it was fake (eCFR). The FTC says brokers of fake reviews “would generally fall under” the ban on selling reviews. On “should have known”, its staff list red flags such as “an unusually large number of reviews” appearing “in a very short period of time” (FTC). If a vendor promises thirty reviews by Friday, you have been warned.

Paying for a sentiment (Section 465.4)

This is the core of “paying for reviews”. A business may not offer compensation or other incentives “conditioned expressly or by implication” on a review “expressing a particular sentiment, whether positive or negative” (eCFR). The rule’s definition of buying a review lists money, gift certificates, discounts, coupons and “contest entries”. The condition can be implied: the FTC’s own example of an illegal offer is “Tell us how much you loved your visit to John’s Steakhouse and get a $5 coupon.” Asking reviewers to add a disclosure does not fix a five star bonus: “No. That conduct would violate Section 465.4” (FTC).

For an HVAC company, “Leave us a five star review and get a discount on your next tune up” breaks this section on its face. So does a raffle entry for “happy customers who share their experience.”

Insider reviews (Section 465.5)

An officer or manager who reviews their own business must clearly disclose the relationship. Owners and managers who ask staff or relatives for reviews have duties too: they must tell those people to disclose, and act if undisclosed reviews appear (eCFR). To the question “Can I ask my family members to write consumer reviews of my business?”, the FTC answers: “Yes, but ask them to clearly and conspicuously disclose their relationship” (FTC). On Google the answer is simpler: content based on a conflict of interest, including “current or former employment” and “familial relationships”, is rating manipulation and gets removed (Google).

Review sites you control (Section 465.6)

You may not present a website or organization you own as an independent source of reviews about a category that includes you (eCFR). A “Best Roofers in Tampa” site that you run, ranking your own company first, is the textbook case.

Review suppression (Section 465.7)

Using “an unfounded or groundless legal threat, a physical threat, intimidation”, or a public accusation you know is false, to stop a review or get it removed is illegal (eCFR). You may still reply publicly, and you may threaten legal action “if you have a legitimate basis for doing so” (FTC). The same section covers your own website: a reviews page may not imply it shows most or all reviews while negative ones are hidden because of their rating.

Fake followers (Section 465.8)

Buying followers, likes or views generated by bots or hijacked accounts, when you “knew or should have known” they were fake, is banned too (eCFR). It is aimed at social media: bot likes bought for a company Facebook page are the kind of thing it targets.

Where the FTC and Google part ways

The gap is the unconditional reward. The FTC says: “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.” It adds a warning: “failing to disclose incentives could be a violation of the FTC Act” (FTC).

Google does not make that distinction. Its policy bans merchants from offering incentives “such as payment, discounts, free goods and/or services” in exchange for “posting any review” (Google). Its help page for owners calls this “strictly prohibited” (Google). The penalty is not a fine but it hurts: Google can remove the reviews, stop new ones for a period, unpublish existing ones, and display a warning that fake reviews were removed (Google). Yelp goes further still and asks businesses not to request reviews at all, let alone offer “freebies, discounts, or payment” (Yelp).

So a gift card for every customer who posts any review is not banned by the FTC rule, though the FTC expects it to be disclosed. On Google it is still a policy violation. If your Google profile brings you work, treat it as off limits.

The same split applies to gating. The FTC rule “does not contain a specific prohibition” against asking only happy customers, though staff say it “could violate the FTC Act” (FTC). Google bans it outright. Our guide on why review gating is banned covers that in detail.

How to stay clean, in six steps

1. Turn down every review seller. No package, no “guaranteed” count, no review swap with another business.
2. Offer nothing for reviews. Not a discount, not a raffle, not a free filter. Thank people instead.
3. Ask every customer the same way. A plain request by text works; see how to ask for a Google review by text.
4. Keep staff and family off your Google profile. If they want to help, they can tell friends about you in person.
5. Never threaten a reviewer. Reply calmly and in public; our guide on responding to a bad Google review has wording you can adapt.
6. Audit what is done in your name. If an agency or software handles reviews for you, ask how it gets them. “Should have known” applies to what you buy.

For the full list of Google’s rules on asking, read Google’s rules on asking for reviews. More on this topic: Google rules.