Asking for Reviews Without Breaking the Law: The FTC Consumer Reviews Rule, Google's Policy and Yelp's, for Contractors

Devon Davila · 2026-10-26

You can ask. You can ask everyone, by text, by email, with a link, after every job. What you cannot do is pay for a sentiment, hide who wrote the review, pick only the customers who will say nice things (Google's rule, and the FTC's older guidance), or threaten the one who did not. Since October 2024 those are federal rule violations with a per-violation penalty that is larger than most jobs, and since December 2025 the FTC has shown it will write to small service businesses, not just Amazon sellers.

Quick answer: Since October 21, 2024, the FTC's Consumer Reviews Rule (16 CFR Part 465) makes six things unlawful with civil penalties of up to $53,088 per violation: fake reviews, paying or rewarding for reviews that express a particular sentiment, undisclosed reviews by owners, employees or their relatives, company-run sites posing as independent, suppressing reviews with groundless legal threats or intimidation, and buying fake followers. Asking every customer for a review is legal under the rule. Offering an incentive is legal under the rule only if it is not conditioned on the review being positive, and the Endorsement Guides still require the reviewer to disclose it. Asking only your happy customers is not a Part 465 violation, but the FTC says it 'could violate the FTC Act,' and Google's policy bans it outright. Yelp bans asking at all. A non-disparagement clause in your contract has been void since the 2017 Consumer Review Fairness Act. The FTC sent its first warning letters under the rule in December 2025 to property managers, law firms and an accounting firm, for exactly the practices small service businesses use: employees recruiting friends and family, and incentives tied to five stars.

The rule: 16 CFR Part 465, effective October 21, 2024

The Federal Trade Commission published the Trade Regulation Rule on the Use of Consumer Reviews and Testimonials on August 22, 2024, effective sixty days later. Its definition of a consumer review is broad: "a consumer's evaluation, or a purported consumer's evaluation, of a product, service, or business that is submitted by the consumer or purported consumer and that is published to a website or platform dedicated in whole or in part to receiving and displaying such evaluations." Google Business Profile, Yelp, Angi, Thumbtack, Nextdoor, Facebook recommendations and your own site's review widget all qualify.

Six sections do the work.

The penalty. Rule violations carry civil penalties under 16 CFR 1.98 of up to $53,088 per violation, the level set January 17, 2025 and carried into 2026 without adjustment. The FTC's August 2024 release said the rule lets the agency "seek civil penalties against knowing violators." Each fake or bought review is a violation.

The first enforcement. On December 22, 2025 the FTC sent warning letters to ten companies. Trade press identified them as six property-management firms, three personal-injury law firms and an accounting firm, flagged for reviews that "misrepresent whether a reviewer's experience was positive or negative, or whether the reviewer used the product or service at all" and for "conditioning compensation or other incentives on reviewers expressing a particular sentiment." The letters "are not formal determinations," but they were sent to local service businesses of roughly a contractor's size, for conduct that came from employees recruiting friends and family.

SectionWhat it bansOperative wordsVerified
§465.2 Fake reviewsWriting, creating, selling, buying or posting a review that "materially misrepresents, expressly or by implication" that the reviewer exists, had experience with the business, or what that experience wasBuying or posting one you "knew or should have known" was fake is enough2026-10-26
§465.4 Buying sentimentProviding "compensation or other incentives in exchange for, or conditioned expressly or by implication on, the writing or creation of consumer reviews expressing a particular sentiment"Positive or negative; "by implication" covers the wink2026-10-26
§465.5 InsidersAn officer or manager writing a review "that fails to have a clear and conspicuous disclosure" of the relationship; soliciting reviews from "immediate relatives, employees, or agents" that end up undisclosed, where the officer encouraged non-disclosure, failed to instruct disclosure, or knew and did nothingException: a general request to all customers2026-10-26
§465.6 Fake independent sitesA business-controlled site or entity that claims to provide independent reviews of the business—2026-10-26
§465.7 Suppression(a) using "an unfounded or groundless legal threat, a physical threat, intimidation, or a public false accusation" to prevent a review or get one removed; (b) claiming displayed reviews "represent most or all the reviews submitted" while hiding the negative onesRemoving reviews for false content, personal data, defamation, discrimination or being off-topic is allowed if applied regardless of sentiment2026-10-26
§465.8 Fake influenceSelling or buying fake followers, views or likes "that they knew or should have known to be fake"—2026-10-26

Errata: what the ranking pages get wrong

ClaimReality
"Offer a discount or gift card for a five-star review"§465.4 bans any incentive "conditioned expressly or by implication" on sentiment. Google bans incentives for any review. Yelp bans asking at all.
"Ask your happiest customers for reviews" (review gating)FTC Q&A: "The rule does not contain a specific prohibition against such conduct. But this practice could violate the FTC Act." FTC guide: "Don't ask for reviews only from customers you think will leave positive ones." Google policy: do not "Discourage or prohibit negative reviews, or selectively solicit positive reviews from customers."
"Have your crew and their families leave reviews to get started"§465.5. FTC Q&A: "Yes, but ask them to clearly and conspicuously disclose their relationship to your business." Google treats "current or former employment" as a conflict of interest and removes the review.
"Put a no-bad-reviews clause in your contract"Void "from the inception" and unlawful to offer under the Consumer Review Fairness Act (15 U.S.C. §45b) since 2017.
"Send a cease-and-desist to the reviewer"§465.7(a) bans "an unfounded or groundless legal threat." A defamation claim with a factual basis is not groundless; a threat to make a true negative review disappear is.
"The penalty is $51,744"$51,744 was the 2024 figure. It is $53,088 per violation since January 17, 2025, unchanged for 2026.
"Incentivized reviews are fine if you don't ask for five stars"Under Part 465, yes. Under the Endorsement Guides (16 CFR 255.5), the reviewer must still disclose the incentive, and the FTC Q&A warns that "failing to disclose incentives could be a violation of the FTC Act."

What you may do: the FTC's own words

The FTC maintains a question-and-answer page on the rule and a 2022 marketer's guide to soliciting reviews. Together they draw the lines.

  • Asking is fine. The rule regulates fake, bought, insider and suppressed reviews. It does not prohibit requesting reviews from customers who used your service.
  • Ask everyone. "Don't ask for reviews only from customers you think will leave positive ones." (FTC guide, January 2022.)
  • Ask only real customers. "Don't ask for reviews from people who haven't used or experienced the product or service."
  • Incentives, carefully. "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." But the Endorsement Guides apply: "When there exists a connection between the endorser and the seller of the advertised product that might materially affect the weight or credibility of the endorsement, and that connection is not reasonably expected by the audience, such connection must be disclosed clearly and conspicuously." A $20 gift card for "a review, good or bad" is legal under the rule only if the review says the customer got the $20. And Google bans it regardless (section 4), so for most contractors the practical answer is no incentives at all.
  • Employees and family: disclose. "Yes, but ask them to clearly and conspicuously disclose their relationship to your business." In practice, a review that opens "I work here" is worth nothing to a homeowner, so this is a rule about what not to bother with.
  • Organizing is not suppressing. "Organizing reviews is not suppressing reviews under the rule." Sorting by date, featuring a review on your site, or flagging a review that violates the platform's rules is fine. Hiding reviews because they are negative while claiming to show them all is not.

The platforms are stricter than the law

The consequence of ignoring a platform rule is not a fine; it is removal of the reviews, a warning badge (Yelp's Consumer Alert), or loss of the profile. For a local contractor the Google profile is the business, so Google's rule is the binding one.

PlatformAskingIncentivesGatingInsidersSourceVerified
Google (Maps and Business Profile)Allowed; Google offers a review linkProhibited: do not "Offer incentives – such as payment, discounts, free goods and/or services - in exchange for posting any review"; Business Profile help: incentives for customers "to post reviews, change reviews, or remove negative reviews is considered fake & misleading content and is strictly prohibited"Prohibited: do not "Discourage or prohibit negative reviews, or selectively solicit positive reviews from customers"Prohibited as "a conflict of interest," including "current or former employment, a contractory or consultory relationship"Maps user-contributed content policy; Business Profile help2026-10-26
YelpProhibited: "Don't ask anyone to review your business, be it customers, mailing list subscribers, friends, family, etc."Prohibited: "Don't offer freebies, discounts, or payment in exchange for reviews"; also "you can't offer incentives for users to remove reviews"Moot, since asking is bannedReviews by friends and family are solicitation under the same pageYelp Support, "Don't Ask for Reviews"; Consumer Alerts program for violators2026-10-26
Federal rule (Part 465)AllowedAllowed if not sentiment-conditioned, with Endorsement Guides disclosureNot a Part 465 violation; "could violate the FTC Act"Allowed only with clear and conspicuous disclosure16 CFR 465; FTC Q&A2026-10-26

The contract clause that is void

The Consumer Review Fairness Act of 2016 makes a form-contract term "void from the inception of such contract" if it "prohibits or restricts the ability of an individual who is a party to the form contract to engage in a covered communication," "imposes a penalty or fee against an individual … for engaging in a covered communication," or transfers the intellectual property in the review. And it is not merely unenforceable: "It shall be unlawful for a person to offer a form contract containing a provision described as void." A non-disparagement line in your service agreement is a violation the day you hand the customer the contract, whether or not anyone ever reviews you.

What the Act does not void: a clause requiring the customer to keep confidential genuinely proprietary information, or a defamation claim over a review that states false facts.

A review request that complies with all three

Send it to every customer, after the job is complete and paid, once, with no reward attached.

Thanks for choosing [Company] for your [service] on [date]. If you have a minute, we'd appreciate an honest review of the work. It helps other homeowners decide, good or bad. [Google review link]

What is deliberately absent: "if you were happy," "five stars," any discount, any mention of a future job, and any link that routes unhappy customers to a private form instead of the public one. That last pattern, the "feedback funnel" many review-request tools sell, is the selective solicitation Google prohibits.

If a customer leaves a false review. Reply publicly and factually, flag it under the platform's policy (false content, off-topic, conflict of interest), and keep records. A review that states false facts about your work can support a defamation claim; a review that states an opinion you dislike cannot, and a letter threatening to sue over it is the "unfounded or groundless legal threat" §465.7(a) names.

If an employee or relative already reviewed you. Ask them to add a disclosure or remove it. Under §465.5, knowing about an undisclosed insider review and doing nothing is itself the violation.

Method and limits

We read each section of the rule at Cornell's Legal Information Institute, the penalty amount in the eCFR, the FTC's releases and guidance on ftc.gov, and the platform policies on Google's and Yelp's own support pages, on the dates shown. The composition of the December 2025 warning-letter recipients comes from trade reporting, since the FTC did not name them. We did not research Angi, Thumbtack, Nextdoor or Facebook policies; each has its own, and all are subject to the federal rule. State consumer-protection statutes can add remedies and are not covered.

Last verified 2026-10-26. Not legal advice.

Can I ask for a review by text right after the job?

Yes. The rule does not restrict how or when you ask, only what you offer and whom you pick. Platform rules apply: Google allows requests; Yelp does not.

Can I give a $25 gift card for any review, positive or negative?

Under the federal rule, yes, if it is genuinely unconditioned and the reviewer discloses it. Under Google's policy, no: incentives "in exchange for posting any review" are prohibited and the reviews are removed. Since nearly all contractor reviews live on Google, treat the answer as no.

Can I ask the customers I know were happy?

The FTC says the practice is not banned by the rule but "could violate the FTC Act," and its guide says not to. Google prohibits selectively soliciting positive reviews. Ask every customer the same way.

Can my office manager post a review?

Only with a clear and conspicuous disclosure that they work for you (§465.5), and Google will remove it as a conflict of interest anyway.

Can I respond to a negative review?

Yes. Responding is not suppression. Threatening the reviewer is.

Can I remove a negative review from my own website's testimonial page?

You can choose which testimonials to feature on your site. What §465.7(b) bans is representing that a displayed set of reviews is "most or all the reviews submitted" when you are hiding the negative ones.

What is the actual exposure?

Up to $53,088 per violation under 16 CFR 1.98, with each fake or sentiment-conditioned review counting separately, plus the FTC's ability to seek consumer redress. The December 2025 letters show the agency reads consumer complaints about small service firms.

Sources

  1. 16 CFR Part 465: §465.1
  2. 16 CFR Part 465 §465.2
  3. 16 CFR Part 465 §465.4
  4. 16 CFR Part 465 §465.5
  5. 16 CFR Part 465 §465.6
  6. 16 CFR Part 465 §465.7
  7. 16 CFR Part 465 §465.8
  8. 16 CFR 1.98 (civil penalty amounts)
  9. FTC press release, final rule (2024-08-14)
  10. FTC press release, warning letters (2025-12-22)
  11. FTC, Consumer Reviews and Testimonials Rule: Questions and Answers
  12. FTC, Soliciting and Paying for Online Reviews: A Guide for Marketers (2022)
  13. 16 CFR 255.5 (Endorsement Guides, material connections)
  14. Consumer Review Fairness Act, 15 U.S.C. §45b
  15. Google Maps user-contributed content policy
  16. Google Maps user-contributed content policy Google Business Profile, get reviews
  17. Yelp Support, Don't Ask for Reviews

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