Review incentives and review gating: what the rules allow

Most local businesses know they need a steady flow of reviews, which are a large part of why the Business Profile does so much work. The confusion is about the rules, because there are three rulebooks that overlap without matching: US law, UK law and each review platform's policy. A practice can be legal and still get a Google profile restricted, and one that slips past a platform's filters can still be illegal.

This post sets the rules side by side for UK and US businesses, then covers what to do and sorts common practices into fine, grey, against platform policy and against the law. Why reviews matter for ranking, and how to reply to them, are in the guide to local SEO.

The Federal Trade Commission's Trade Regulation Rule on the Use of Consumer Reviews and Testimonials, at 16 CFR Part 465, was approved 5-0 in August 2024,¹ published in the Federal Register on 22 August 2024² and in force from 21 October 2024.³ What it adds is money: courts can impose civil penalties for knowing violations.³ It prohibits:

• Fake or false reviews: writing or selling reviews that misrepresent who the reviewer is, whether they used the product or what their experience was, and buying or spreading them where the business knew or should have known.² AI-generated fakes are included.¹
• Incentives conditioned, expressly or by implication, on a review being positive or negative,² on third-party platforms as well as the business's own site.³
• Reviews by officers or managers that do not clearly disclose the relationship, and officers or managers asking staff or immediate relatives for reviews that then appear undisclosed. A general request to all purchasers is excluded.²
• Review suppression: unfounded legal threats, intimidation or knowingly or recklessly false accusations used to stop or remove a review, and hiding reviews by rating while implying the rest are all or most of them. Removing reviews on neutral grounds, such as abuse or irrelevance, is allowed.²
• Company-controlled review sites posing as independent, and bought followers or views used for a commercial purpose.²

What the rule leaves to the Endorsement Guides

The rule does not ban incentives that carry no condition on sentiment, and it has no specific ban on asking only satisfied customers, though the FTC says both can still break the FTC Act.³ The Endorsement Guides at 16 CFR Part 255 cover them. An incentive has to be disclosed whether or not a review is required in return, and if incentivised reviews materially lift the average star rating, the average may need a disclosure too. Paying for reviews that must be positive is deceptive even when the payment is disclosed.⁴

On gating, the Guides describe a marketer that invites only its very happy buyers to post reviews. That may be unfair or deceptive if it makes the reviews substantially more positive, while inviting every recent buyer is fine even if the marketer says it hopes for good reviews.⁴ The FTC's guide for marketers adds a practical point: know each platform's rules before you ask.⁵

US enforcement

The FTC's first case about hiding negative reviews came in January 2022. Fashion Nova's review tool posted four- and five-star reviews automatically and held back lower ratings from late 2015 to November 2019, and the retailer agreed to pay $4.2 million.⁶ Under the new rule, the FTC warned 10 unnamed companies in December 2025 that violations could bring civil penalties of up to $53,088 each. The letters were not findings of a breach.⁷

In April 2026 the FTC charged the supplement seller TruHeight under the FTC Act and the reviews rule, alleging that employees wrote thousands of the five-star reviews on its website and that it offered free or discounted products for five-star reviews.⁸ The final order in July 2026 required a $750,000 payment.⁹ Closest to local search, in May 2026 the FTC and Illinois took action against a Chicago company, Premium Home Service, in a complaint citing the reviews rule among other laws. It alleges that the company created thousands of online profiles for home repair firms that did not exist and used fabricated five-star reviews to dilute real one-star ones. Those are allegations.¹⁰

Paragraph 13 of Schedule 20 to the Digital Markets, Competition and Consumers Act 2024 lists the review practices that are banned in all circumstances, and it came into force on 6 April 2025. It bans submitting, or commissioning someone else to write, a fake review or one that conceals it was incentivised; publishing reviews or ratings in a misleading way; publishing reviews without reasonable and proportionate steps to prevent and remove banned ones; and offering traders services that do or facilitate the first two. Commissioning includes incentivising by any means, and misleading publication includes hiding negative reviews or giving positive ones greater prominence.¹¹

What the CMA's guidance adds

The CMA's guidance, published on 4 April 2025, fills in the detail. Its examples of commissioning include asking for a review in exchange for money, discounts or vouchers, free products or invitations to events, and a trader asking a member of staff to review its product. Its examples of banned commissioning include offering a free or discounted product for a five-star review that does not reflect the customer's genuine experience, and offering a refund or gift card if a customer changes a negative review so it no longer reflects theirs.¹²

Incentives as such are legal if consumers are told the review was incentivised and it reflects a genuine experience. Where a platform does not allow incentivised reviews, though, the CMA says submitting one is likely to be misleading. A prize draw, which does not guarantee the reviewer a direct benefit, is unlikely to count as commissioning at all.¹²

Asking is fine: emailing customers generally to ask if they want to leave a review, without predetermining the content or sentiment, is not prohibited. The guidance warns against suppressing genuine negative reviews, for example through threats of legal action, by arbitrarily stopping and starting review invitations, or by making a complaint's resolution depend on the customer not leaving a negative review. It also warns against cherry-picking, including encouraging only satisfied customers to leave reviews. Those sit under publishing, and a trader that shows its rating from a review site on its own website counts as a publisher.¹²

UK enforcement

Since 6 April 2025 the CMA can decide for itself that consumer law has been broken, without going to court, and fine a business up to 10% of its global turnover.¹³ Its investigation of Google and Amazon, opened under the old regime, ended in undertakings. In January 2025 Google agreed that UK businesses found boosting their rating with fake reviews would get a warning on their profile and have new reviews switched off, with repeat offenders having all their reviews deleted for six months or more. It said it planned to extend the business sanctions beyond the UK by the end of 2025.¹⁴ Amazon gave undertakings for its UK store in June 2025.¹³

The CMA has also reviewed more than 100 review publishers, wrote to 54 of them and says 90% made changes. In March 2026 it opened investigations into five businesses over reviews. Two are close to everyday local practice: Dignity, over whether it asked staff to write positive reviews of its crematoria, and Pasta Evangelists, over whether it gave customers discounts on future orders for five-star reviews on delivery apps without disclosing it.¹⁵ No findings have been made, and on 14 October 2026 the CMA said the cases were ongoing.¹⁶

Platform policies are stricter than the law in both countries, and a platform can act on its own without waiting for a regulator. This is where four of them stand on their current help pages.

Google's Maps policy also bans reviews based on a conflict of interest, including current or former employment, and prohibits asking staff to collect a set number of reviews or reviews that name a member of staff.¹⁷ That covers a business asking its staff to get customers to mention them by name. When Google finds that an owner has broken its fake engagement policy, it can restrict the profile as well as removing the reviews, and it emails the owner before doing so. The help page describing those restrictions names no particular country.¹⁸

Yelp needs separate handling, because a request that is fine on Google goes against Yelp's policy.²¹ I would leave Yelp out of review requests entirely and let customers find it on their own.

Google's tips for getting more reviews include reminding customers to leave one.²⁴ The steps below do that within the rules above, Yelp aside.

The grey areas

• Disclosed incentives for any review. These are legal in both countries with disclosure,¹²⁴ but all four platforms above prohibit them,^17192122 which leaves only your own website. For most local businesses I do not think it is worth the trouble.
• Prize draws. A draw is unlikely to count as commissioning under UK law,¹² but Trustpilot names prize draw entries as an incentive¹⁹ and Google's ban on incentives for reviews makes no exception for them.¹⁷ I would not run one for Google reviews.
• Contacting an unhappy reviewer. Fixing the problem is fine, and the FTC says contacting unhappy customers to resolve their issues is not prohibited by the rule.³ Making a refund conditional on changing the review is banned in the UK¹² and against Google's policy.¹⁷ Fix it, then leave any update to the customer.
• Choosing reviews for your own site. Giving positive reviews greater prominence than negative ones can be misleading under UK law,¹¹ and hiding reviews by rating while implying the rest are all or most of them is suppression under the US rule.² I would show a selection with a link to the full profile.

The diagram sorts common practices against Google's policy and UK law, where the lines are sharpest. In the US, disclosed incentives and gating are not banned by the FTC rule itself, though the FTC Act can still reach both.³

Yelp aside, the routine that satisfies every rulebook here is simple: ask everyone the same way at the same moment, and keep incentives and staff out of it.