FTC Fake Review Rule (16 CFR Part 465)

The FTC Rule on the Use of Consumer Reviews and Testimonials (codified at 16 CFR Part 465, in force since October 2024) is the first US federal rule that gives the FTC explicit civil-penalty authority over a broad set of deceptive review practices.

What's prohibited:

• Fake or fabricated reviews — AI-generated, written by people who didn't use the product, or written by people who don't exist.
• Buying or selling fake reviews, including brokering services that produce them.
• Insider reviews without disclosure — reviews by employees, contractors, or anyone with a material connection to the business, without clear disclosure.
• Undisclosed compensated reviews — paying for reviews without disclosing the payment.
• Review suppression — using legal threats, payments, or technical mechanisms to prevent customers from posting honest negative reviews.
• Review gating — see review gating.
• Fake testimonials presented as if from real customers.
• Manipulation of company-controlled review sites when those sites are presented as independent.
• Buying followers, likes, or engagement from bots or paid services to mislead about popularity.

Penalties: civil penalties currently up to approximately $51,744 per violation under 15 U.S.C. § 45(m)(1)(A), adjusted annually for inflation.

Who it applies to: any business operating in the US, regardless of size or industry. Platforms that knowingly host violating content can also be liable.

What this means for review software: any platform you use must support compliance by default — no review gating in the destination routing, no synthetic reviews from AI features, clear consent capture for incentivized review programs, and audit logs proving what was sent to whom. Vouch is designed with these guardrails built in; see our Acceptable Use Policy.