The FTC reviews rule, for contractors
The Rule on the Use of Consumer Reviews and Testimonials went into effect on October 21, 2024. Here is what it bans, in the FTC's own words, with each part tied to a situation a painter, plumber or roofer actually meets.
One federal rule, in plain terms.
Everything in this section is quoted from the FTC's own pages about the rule. The links are at the bottom of the page.
Its full name is the Rule on the Use of Consumer Reviews and Testimonials, filed as 16 CFR Part 465. The FTC's rulemaking page records that "Following receipt of public comments and informal hearings, the final rule was approved by the Commission in August 2024," and its questions and answers page says the rule "went into effect on October 21, 2024." It has been in force for close to two years.
On what it carries, the questions and answers page says the rule "authorizes courts to impose civil penalties for knowing violations." Asked whether there is a private right of action under it, the same page answers: "No, the rule does not provide a private right of action." That is as far as this guide goes on enforcement, and it is as far as the FTC's page goes.
What a contractor needs from the rule is the list of things it bans, because every one of them turns up, sooner or later, as a helpful suggestion from somebody. The list below is the FTC's, in the FTC's words, with the situation beside each.
What it prohibits, and where a trade meets each one.
The descriptions are quoted from the FTC's announcement of the final rule. The situations are ours.
Fake or false reviews. The rule covers reviews that "misrepresent that they are by someone who does not exist, such as AI-generated fake reviews, or who did not have actual experience with the business or its products or services, or that misrepresent the experience of the person giving it." Where a trade meets it: the nephew with three email accounts offering to get the new profile started, and the vendor who calls the same thing seeding. The questions and answers page puts it plainly: "Your business could be liable if it wrote or created fake or false reviews or if it purchased consumer reviews that it knew or should have known were false."
Buying positive or negative reviews. The rule "prohibits businesses from providing compensation or other incentives conditioned on the writing of consumer reviews expressing a particular sentiment, either positive or negative. It clarifies that the conditional nature of the offer of compensation or incentive may be expressly or implicitly conveyed." Where a trade meets it: the gift card for a good review, said out loud or just understood. Asked whether paying for top-rated reviews on a third party platform is fine if the reviewer adds a disclosure, the FTC answers: "No. That conduct would violate Section 465.4. Note also that this section applies whether the reviews appear on your website or third-party review platforms."
Insider reviews. The rule prohibits certain reviews "written by company insiders that fail to clearly and conspicuously disclose the giver's material connection to the business." Where a trade meets it: your office manager, your foreman, your brother-in-law. To a small business owner asking about family, the questions and answers page says: "Yes, but ask them to clearly and conspicuously disclose their relationship to your business." And it adds a caution that applies even with the disclosure made: "if these reviews materially increase the average star rating of a product, the business could be violating the FTC Act even with such disclosures, because consumers might see only the star rating and not look at the individual reviews."
Company-controlled review websites. The rule "prohibits a business from misrepresenting that a website or entity it controls provides independent reviews or opinions about a category of products or services that includes its own products or services." Where a trade meets it: the best roofers in your town site that you happen to own, ranking you first. Rare in the trades, and the rule names it anyway.
Review suppression. The rule "prohibits a business from using unfounded or groundless legal threats, physical threats, intimidation, or certain false public accusations to prevent or remove a negative consumer review." It "also bars a business from misrepresenting that the reviews on a review portion of its website represent all or most of the reviews submitted when reviews have been suppressed based upon their ratings or negative sentiment." Where a trade meets it: the lawyer letter over a one star, and the reviews page on your own site that only ever shows the good ones.
Fake social media indicators. The rule "prohibits anyone from selling or buying fake indicators of social media influence, such as followers or views generated by a bot or hijacked account." Where a trade meets it: the offer to grow the company page to a few thousand followers by Friday.
The six descriptions are quoted from the FTC's announcement of the final rule, the dates from its rulemaking page, and the answers from its questions and answers page. Read them yourself before deciding anything on them.
The rule and the ordinary ask.
Most of the rule is about things a contractor never does. Two of its answers are about the thing you do every week.
The first is the exception for ordinary asking. The questions and answers page says: "Section 465.2(d) of the rule provides an exception for reviews that resulted from a business making generalized solicitations to purchasers to post reviews about their experiences with a product, service, or business." To a company that emailed all its recent customers for a review and found a few employees among them, the page answers that the company "didn't violate this section of the rule, which exempts generalized solicitations to purchasers for them to post reviews about their experiences with the product, service, or business." The word doing the work in both is generalized: the ask that goes to everyone.
The second is the question every contractor is really asking. The FTC's page puts it exactly: "Can my business ask for reviews only from customers whom we think are happy with our services?" And answers, in full: "The rule does not contain a specific prohibition against such conduct. But this practice could violate the FTC Act."
The first says the rule does not name the practice. The second says the FTC thinks it could break the broader law it enforces. We leave both exactly as written, and if you want to know what "could" means for your business, that is a question for a lawyer, not for a marketing page.
Google's policy addresses the same practice directly on its own page, listing "Discourage or prohibit negative reviews, or selectively solicit positive reviews from customers" among the things it does not allow merchants to do. A Google review has to sit inside the FTC's rule and Google's policy at once, and the ask that goes to everyone, with nothing attached, is inside both.
Both sources are short and public. Read them yourself at Google's user contributed content policy for Maps and at the FTC's questions and answers on the rule. We are not lawyers, and none of this is legal advice.
What staying inside it looks like.
None of this needs a compliance department. It needs a habit.
- Ask everyone. The exception the rule carves out is for generalized solicitations, and the sort is the practice the FTC says could violate the FTC Act.
- One message, one link. The same words every time, and nothing in them that hints at the rating you hope for.
- Nothing in exchange. No compensation or incentive conditioned on sentiment, and nothing offered for an edit or a takedown.
- No insiders, no family. The rule requires disclosure; Google's policy calls the relationship a conflict of interest. Leaving them out satisfies both.
- Reply, do not threaten. A public reply is allowed. A false accusation, intimidation, or a groundless legal threat is what the rule names.
- No bought followers. The company page grows at the speed the company does.
It asks every completed job for an honest Google review, in the same words, and never filters. There is no version of it with a filter. It is the optional service described on our reviews page, and the asking is one part of it. What your customers write is theirs.
More on reviews: Is review gating illegal? · What Google lets you ask for in a review · How to ask for reviews honestly
Every guide on this site, the cost pages and the rules for asking for reviews, in one place: see the guides →
Questions about the rule.
Can I still ask customers for reviews at all?
Yes, and the rule says so in its own terms. The FTC's page explains that "Section 465.2(d) of the rule provides an exception for reviews that resulted from a business making generalized solicitations to purchasers to post reviews about their experiences with a product, service, or business." The word doing the work is generalized: the ask that goes to everyone who bought from you. A message sent to every completed job, in the same words, is the plainest form of that.
Can I offer a small thank you for a review?
The FTC's page 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 that an incentive a business merely expects will produce a positive review is not by itself such a requirement, but that "such a practice could violate the FTC Act." Google's policy, separately, does not allow incentives "in exchange for posting any review or revision or removal of a negative review." A Google review sits inside both, and offering nothing satisfies both.
What can I say when I reply to a bad review?
The FTC's page says: "Yes, you can respond publicly to the review, and yes, you should watch what you say. The rule prohibits making a false accusation about the reviewer if you know that the accusation is false or make it with reckless disregard as to its truth or falsity." It defines intimidation as more than physical threats, naming "abusive communications, stalking, character assassination, and sexual harassment" when used to force or deter someone. So the reply is short, factual, and calm, and it says what you would do to put it right.
Can I ask a customer to take a review down, or change it?
You can talk to them. The FTC's page says the rule does not prohibit contacting customers who post negative reviews to resolve the reported issues, and adds: "It also does not prohibit simply asking satisfied customers to update their reviews." What it names is the pressure and the payment. Asked about offering compensation to remove or change a review, the page answers: "No, but paying consumers to change or remove truthful negative reviews may violate the FTC Act as an unfair or deceptive act or practice." Fix the job. Do not buy the edit.
Who enforces it?
The FTC's page says the rule "authorizes courts to impose civil penalties for knowing violations." Asked whether there is a private right of action under it, the page answers: "No, the rule does not provide a private right of action." That is the whole of what this guide says about enforcement, because that is the whole of what the FTC's own pages say. If you want it applied to your particular business, that is a job for a lawyer rather than for a marketing page.
That is the rule.
Six things banned, two answers about asking, and a habit that keeps a trade inside all of it: ask everyone, the same way, with nothing attached. If you would rather that habit ran itself on every finished job, a short call is where it starts.