Incentivized reviews
paying for reviews / review for a discount / buying reviews / review incentives
An incentivized review is one a customer wrote after being offered something for it. The FTC rule does not ban that. It bans conditioning the incentive, expressly or by implication, on the review expressing a particular sentiment. Adding a disclosure does not fix a five-star requirement.
The line is narrower and clearer than most people expect, and it is not where they think. Section 465.4 makes it an unfair or deceptive act for a business to provide compensation or other incentives in exchange for, or conditioned expressly or by implication on, the writing of consumer reviews expressing a particular sentiment, whether positive or negative. Sentiment is the word doing the work. Not payment. Sentiment.
The Commission says so directly in its own questions and answers: the rule does not prohibit giving incentives for reviews, as long as there is no express or implied requirement that the reviews express a particular sentiment. It adds a second warning in the same breath, that failing to disclose incentives could itself be a violation of the FTC Act.
Then it closes the escape hatch people reach for first. Asked whether a business can pay for five-star reviews on third-party platforms if reviewers are asked to disclose the incentive, the answer given is no, and that such conduct would violate section 465.4. A disclosure makes a paid review honest about being paid. It does nothing about a requirement to be positive.
One quieter point is worth knowing, because it changes who carries the risk. The Commission states that ordinary consumers cannot be liable under the rule for what they say or do not say in reviews. The obligations run to businesses. The customer who took your ten dollar voucher is not the one exposed.
In practice
The phrase to listen for is the one that sounds harmless. Leave us a review and get ten percent off is a different sentence from leave us a five star review and get ten percent off, and the rule reaches implication as well as wording. A campaign that only rewards the customers who left four or five stars has made the requirement real without ever printing it.
Not the same as
- Fake reviews
- Those concern reviews from people who do not exist or never used the business. This concerns real customers writing under a condition.
- Asking for reviews
- Requesting reviews is not what the rule addresses. What you attach to the request is.
Why it matters to you
Review campaigns are sold to businesses constantly, and the packaging often carries the exact defect the rule names. The Commission also notes that incentivized reviews count as consumer testimonials under the rule, which pulls them into provisions a business would not think applied to a Google review. Before running anything, the question is simple: does getting the reward depend in any way on what the review says?
What to ask or check
- 01Does the reward depend, in wording or in practice, on the review being positive?
- 02Is the incentive disclosed, and separately, is it conditioned on sentiment?
- 03Are we rewarding only the customers who left high ratings, which makes the condition real?
What people get wrong
That paying for reviews is the problem. The rule targets conditioning the reward on a particular sentiment, and the Commission says a disclosure does not cure a five star requirement.
Red flags
- A review campaign that rewards only customers who left four or five stars.
- An incentive offered with a disclosure, presented as making a five star requirement acceptable.
- A supplier promising a number of positive reviews rather than a number of requests sent.
Who owns it
The business. The Commission states that ordinary consumers cannot be liable under the rule for what they say in reviews, so using an outside agency moves the work, not the exposure.
Where you will see it
In review generation proposals, receipt inserts, follow-up emails and texts after a job.