Trade Regulation Rule on the Use of Consumer Reviews and Testimonials
The Federal Trade Commission ("FTC" or "Commission") is issuing this final rule and Statement of Basis and Purpose ("SBP") relating to certain specified unfair or deceptive acts or practices involving consumer reviews or testimonials. This final rule, among other things, prohibits selling or purchasing fake consumer reviews or testimonials, buying positive or negative consumer reviews, certain insiders creating consumer reviews or testimonials without clearly disclosing their relationships, creating a company-controlled review website that falsely purports to provide independent reviews, certain review suppression practices, and selling or purchasing fake indicators of social media influence.
What this rule actually says
The FTC just made it illegal to buy fake reviews, pay for positive reviews, or suppress negative ones. It also blocks insider employees from posting reviews without disclosing they work for the company, and bans fake "independent review" websites that are actually company-controlled. The rule is designed to stop the review manipulation playbook that's become routine in e-commerce and SaaS.
Who it applies to
- If you're soliciting user reviews or testimonials: you can't pay for positive ones, and you can't buy negative ones to bury them.
- If employees or contractors are leaving reviews: they must clearly disclose their relationship to the company (e.g., "I work here" in their review).
- If you're running a review/comparison site about your own product: you can't make it look independent when it's actually company-controlled.
- If you're buying fake social media follower counts or engagement metrics: that's covered too.
- Jurisdiction: This is a U.S. federal rule, so it applies to any founder selling to U.S. customers, regardless of where you're incorporated.
- Which AI products trigger this: Any AI tool with a public-facing user review section—medical scribes with customer testimonials, hiring assistants with case studies, support chatbots with ratings. Basically anything users rate or comment on.
- What's out of scope: Internal feedback, private beta tester comments, and your own honest product descriptions aren't covered.
What founders need to do
- Audit your reviews and testimonials (2–3 hours): Check if any reviews are purchased, paid-for, or undisclosed employee posts. Flag and remove anything that violates the rule.
- Add disclosure language to employee/team reviews (1 hour): If your co-founder or team member leaves a public review, they must say so. Add a standard template: "I'm [Name], [Your Company] founder/employee."
- Stop paying for reviews (1 hour): Delete any relationships with review-buying services or paid testimonial platforms. If customers want to leave reviews, let them—unprompted.
- Document your review policy (2–3 hours): Write and publish a simple policy explaining that reviews are unpaid and user-submitted. This protects you if a review later turns out to be fake.
- Monitor ongoing (15 min/month): Spot-check new reviews for obvious fakes or undisclosed relationships. The FTC will go after serial offenders, not one-off edge cases.
Bottom line
Act now if you're actively buying reviews or have employees posting without disclosure; otherwise, monitor your review practices and document a clean policy.