The FTC fake reviews rule turned common review habits into violations that can carry civil penalties. Formally it's the Trade Regulation Rule on the Use of Consumer Reviews and Testimonials, and it has applied since October 21, 2024. The rule itself draws about 20 searches a month. The temptation it targets draws far more: "fake google reviews" gets 880 searches a month and "buying google reviews" 5,400 (Google Ads Keyword Planner data via DataForSEO, US, 12-month average to Sep 2026). This guide explains what the rule bans and how Google's review policy layers on top. It ends with what an honest review request from a practice looks like.
What the FTC rule on reviews prohibits
The rule is codified at 16 CFR Part 465 (opens in a new tab), published at 89 FR 68077 on August 22, 2024 (checked in the eCFR on October 23, 2026). The FTC's questions-and-answers page (opens in a new tab) confirms it "went into effect on October 21, 2024."
| Section | What it bans, in short | Where a practice could trip |
|---|---|---|
| § 465.2 | Fake reviews and testimonials: invented reviewers, or people who never had the experience | Buying reviews; posting "patient stories" that never happened |
| § 465.4 | Incentives conditioned, expressly or by implication, on a positive or negative review | "Leave us 5 stars and get $20 off" |
| § 465.5 | Undisclosed reviews by owners, managers and, in some cases, staff and relatives | Owner's spouse leaving a review |
| § 465.6 | A company-controlled site posing as an independent reviewer | A "best dentists in town" site you secretly run |
| § 465.7 | Suppressing reviews with threats or false accusations, or hiding negative reviews while implying you show them all | Legal threats over a bad review; filtering your website's review widget |
| § 465.8 | Buying or selling fake followers or engagement for a commercial purpose | Purchased followers for the practice account |
Penalties, as verified. Because Part 465 is a trade regulation rule, a knowing violation falls under Section 5(m)(1)(A) of the FTC Act. The statute sets "not more than $10,000 for each violation" (15 U.S.C. 45 (opens in a new tab)), and the FTC adjusts that figure for inflation. The current amount in 16 CFR 1.98(d) (opens in a new tab) is $53,088 per violation, from the January 17, 2025 adjustment, as shown in the eCFR on October 23, 2026. Check that section before quoting a figure, because it changes.
Conduct the rule doesn't reach can still be deceptive under the FTC Act, and Google can remove reviews under its own policy. Not sure what your listing and reviews look like from the outside? The free marketing audit checks your Google listing and reviews along with your website, SEO, AI visibility, social and ads.
Buying or writing fake reviews
Section 465.2 bars writing, creating, selling, buying or disseminating a review or testimonial that "materially misrepresent[s], expressly or by implication," that the reviewer exists or actually used the service. For a practice, that covers:
- paying a vendor for a batch of five-star reviews;
- staff writing reviews under invented names;
- an agency posting reviews "on your behalf";
- website "testimonials" from composite or invented patients, including AI-written ones.
Google's Maps content policy (opens in a new tab) bans the same conduct from its side: "Content that is not based on a real experience," "Reviews or ratings that have been paid for, directly or in kind," and content "posted from multiple accounts by or at the request of one person." A review you didn't earn can come down under either set of rules.
If you're on the receiving end, with suspicious reviews posted about your practice, see our guide to fake Google reviews for how to report them.
Incentives tied to positive reviews
The core text of § 465.4: it is unlawful "for a business to provide 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, whether positive or negative."
The FTC's Q&A adds two points. The rule doesn't ban every incentive, only those tied to sentiment, but failing to disclose an incentive "could still violate the FTC Act." And paying for five-star reviews is prohibited even if you ask reviewers to disclose the payment.
For a practice, three more layers make incentives a poor idea even when they're neutral:
- Google forbids them outright. Merchants may not "Offer incentives – such as payment, discounts, free goods and/or services" in exchange for a review.
- Federal anti-inducement law. The civil monetary penalties law covers offering remuneration to a Medicare or Medicaid beneficiary that the provider "knows or should know is likely to influence" them to choose that provider (42 U.S.C. 1320a-7a(a)(5) (opens in a new tab)). "Remuneration" includes "transfers of items or services for free or for other than fair market value." Whether a review reward crosses that line is a question for counsel, alongside HHS OIG's guidance on gifts to beneficiaries.
- Your professional code. Some codes restrict soliciting testimonials at all; see the FTC Endorsement Guides page for the psychologist example.
Illustrative example (fictional practice). Non-compliant: Copperfield Dental's receipt says "Leave us a 5-star Google review and get $25 off your next cleaning." That's a sentiment-conditioned incentive under § 465.4, a Google violation, and a potential inducement for any Medicare or Medicaid patient. Compliant: "We'd value your honest feedback on Google," with the link and no reward.
Reviews from staff, owners and relatives
Part 465 defines officers to "include owners, executives, and managing members," and an immediate relative as "a spouse, parent, child, or sibling." Three duties follow:
- Owners and managers who write a review of their own business must clearly disclose their "material relationship to the business" (§ 465.5(a)).
- Testimonials from staff or agents that the business shares must disclose the relationship when it isn't obvious and the business knew or should have known about it (§ 465.5(b)).
- Soliciting reviews from relatives, staff or agents. An owner or manager violates § 465.5(c) when such a request produces an undisclosed review and the manager encouraged non-disclosure, didn't instruct disclosure, or knew and failed to fix it.
There's an exception for "generalized solicitations to purchasers." The FTC's Q&A says that if you email every recent customer asking for reviews and an employee who happens to be on that list posts without disclosure, the business hasn't violated the rule.
| Reviewer | FTC rule | Google's policy |
|---|---|---|
| Owner or manager | Allowed only with a clear disclosure | Conflict of interest; not allowed |
| Employee | Must disclose if you asked them | "Current or former employment" is a listed conflict |
| Spouse, parent, child, sibling | Must disclose if you asked them | Personal affiliations can be a conflict |
| Patient who got a generalized request | Fine | Fine |
Google's conflict-of-interest rule means a disclosed staff review can satisfy the FTC and still be removed. The simplest policy: staff and family don't review the practice.
Suppressing or gating negative reviews
Section 465.7 covers two kinds of suppression. The first is using "an unfounded or groundless legal threat, a physical threat, intimidation, or a public false accusation" to stop or remove a review. The second is implying that the reviews on your own website "represent most or all the reviews submitted" while you hide reviews because of their rating or negative sentiment.
You may still remove reviews from your own site under criteria applied to every review regardless of sentiment. The rule lists examples such as defamatory or harassing content, personal information, content that's clearly false and reviews unrelated to your services.
Review gating means asking whether a patient was happy and sending only the happy ones to Google. The FTC's Q&A says "The rule does not contain a specific prohibition against such conduct" but that it could still violate the FTC Act. It cites the Endorsement Guides, which warn against procuring or suppressing reviews in ways "distorting or otherwise misrepresenting what consumers think" (16 CFR 255.2(d) (opens in a new tab)). Google is explicit: merchants may not "Discourage or prohibit negative reviews, or selectively solicit positive reviews from customers." Our page on review gating rules shows the patterns to remove from your follow-up messages.
When a bad review lands, answer without confirming the person is your patient. Their identity combined with their care is individually identifiable health information (45 CFR 160.103 (opens in a new tab)). See responding to reviews safely for wording.
What a compliant review request looks like
A compliant request is boring by design: the same words to everyone, no reward, no sentiment filter.
- Pick a consistent rule: every patient seen that week, or every patient after a completed visit.
- Send the same message to all of them, with a direct link to your Google review form.
- Offer nothing in exchange, not even an entry into a draw.
- Don't pre-screen. No "Were you happy? Yes/No" step before the link.
- Leave staff and family off the list, and don't ask them to recruit relatives.
- Reply to every review the same way, without confirming anyone is a patient.
Illustrative example (fictional practice). "Thanks for visiting Meadowbrook Physical Therapy. If you have a minute, we'd appreciate an honest review of your experience on Google: [link]. Please leave out any health details you'd prefer to keep private."
Medfy does not send review requests. For building a steady, compliant flow of reviews, see our guide to getting more Google reviews, and for how this rule sits next to platform and board rules, the overview of medical advertising regulations.
This is general information, not legal advice. Confirm how it applies to your practice with a qualified advisor.
Frequently asked questions
Is it illegal to buy Google reviews?
Buying reviews that misrepresent who wrote them or what they experienced violates the FTC's Consumer Reviews and Testimonials rule, in effect since October 21, 2024. Paying for positive reviews is banned even with a disclosure. Knowing violations can bring civil penalties, listed at up to $53,088 per violation in the FTC's 2025 inflation adjustment. Google's own policy separately prohibits reviews paid for in cash or in kind.
Can I offer patients a discount for leaving a review?
Don't. The FTC rule bans incentives conditioned on positive sentiment, and the FTC says even neutral incentives should be disclosed. Google's policy goes further and prohibits offering payment, discounts or free services in exchange for a review at all. For Medicare or Medicaid patients, a discount can also raise federal beneficiary-inducement questions. Asking every patient the same way, with no reward, avoids all three problems.
Can my staff leave reviews for the practice?
Under the FTC rule, owners and managers who review their own business must disclose the relationship, and a manager who asks staff or relatives for reviews must make sure they disclose it too. Google treats current or former employment as a conflict of interest and doesn't allow those reviews, disclosed or not. The practical answer is to keep staff, owners and their families out of your Google reviews.
Can I ask only happy patients for reviews?
No. The FTC rule doesn't name review gating specifically, but the FTC says selectively asking customers likely to be happy can be misleading under the FTC Act and its Endorsement Guides. Google's policy prohibits merchants from selectively soliciting positive reviews or discouraging negative ones. Send the same request to every patient, or to everyone seen in a set period, and don't route anyone to a private complaint form first.