Using online reviews as testimonials within FTC rules

The Federal Trade Commission's Guides Concerning the Use of Endorsements and Testimonials in Advertising sit at 16 CFR Part 255. The FTC revised them in 2023. The Guides are not a rule by themselves, but they explain how the FTC applies the law against deceptive advertising to endorsements, and a review you quote in your marketing counts as an endorsement.

The main points that matter when you use online reviews as testimonials are these.

• Honest opinions: an endorsement must reflect the honest opinion and real experience of the person giving it
• No distortion: you must not reword a review or take it out of context in a way that changes what the reviewer meant
• Still current: you should have good reason to believe the reviewer still holds the view, so very old quotes about a product that has changed deserve a second look
• Typical results: if a quote describes a result most customers do not get, you need to clearly disclose what people can generally expect
• Material connections: if the reviewer has a connection to you that readers would not expect, such as payment, a free product, a discount, employment or a family tie, it must be clearly disclosed
• Review manipulation: the 2023 revision says that procuring, suppressing, boosting, organizing or editing consumer reviews in ways that distort what consumers actually think is deceptive

The Guides also make clear that advertisers can be responsible for what their endorsements say, not only the people who wrote them.

In 2024 the FTC adopted a Trade Regulation Rule on the Use of Consumer Reviews and Testimonials, at 16 CFR Part 465, in effect since October 2024. Unlike the Guides, this is a rule, and the FTC can seek civil penalties against businesses that knowingly violate it. Its main prohibitions are these.

• Fake reviews and testimonials: reviews by people who do not exist, who never used the product, or that misrepresent the reviewer's experience, including ones generated by software; businesses may not create, sell, buy or spread them when they know or should know they are fake
• Buying sentiment: offering compensation or incentives in exchange for reviews that express a particular sentiment, positive or negative
• Insider reviews: reviews or testimonials by officers, managers, employees or agents, or their relatives, without clear disclosure of the relationship, in the situations the rule describes
• Company controlled review sites: presenting a website or entity you control as an independent source of reviews about your own products
• Review suppression: using unfounded legal threats, intimidation or false accusations to stop or remove reviews, and claiming that the reviews shown on a review section of your site are all or most of the reviews when some were held back because of their rating or negative sentiment
• Fake social media indicators: buying or selling fake followers or views to misrepresent influence

For anyone using online reviews as testimonials, the practical message is clear: use only real reviews, never pay for positive ones, disclose connections and do not hide or misrepresent the negative side.

Picking your strongest quotes for a pricing page or a homepage is a normal marketing practice. What matters is that the selection does not create a false impression.

• Do not present a hand picked set of quotes as if it were your complete review history
• Do not imply an average rating you do not have; if you show a rating, show it as the source displays it, with a link
• Do not use a quote about an exceptional result as if it were typical; add a note about what customers generally see
• Do not keep quotes that no longer describe your product, price or service
• If you run a section that claims to show all reviews, show all of them

A source link next to each quote helps here, because any reader can check the original and see the context.

Beyond the law, every review site has its own terms of service. The reviewer generally owns the words they wrote, and the site's terms govern how the content may be reused, copied or displayed elsewhere. Some sites offer official widgets, some publish guidelines for quoting reviews in marketing, usually with attribution and a link, and some restrict automated collection. Google's official place data, for example, requires attribution and limits how long the content may be stored.

In practice that means three things. Read the terms of each site you quote. Use official widgets, official data or the site's published guidelines where they exist. And avoid any tool that collects reviews in ways a site forbids. Our page on the Google reviews scraper explains how we handle Google reviews through official place data and what that does not include.

Good attribution protects you and persuades the reader. For every quote, keep the following.

• The reviewer's name exactly as published, whether that is a full name, a first name and initial, or a handle
• Role and company only if the reviewer published them
• The site the review came from and a link to the original
• The reviewer's exact words, with any trim marked by an ellipsis
• No photos unless the reviewer published them with the review and the platform allows reuse

Using a person's name or likeness in advertising can also raise state law questions about publicity rights. Quoting a public review with its author as published and a link is a common practice, but for prominent uses, such as a large photo in a paid ad, asking the reviewer for permission is the safest route. Our customer testimonials guide covers attribution in more depth.

If you ask customers for reviews, the incentive question comes up quickly. Under the FTC rule, offering anything conditioned on a positive review is prohibited. Under the Guides, an incentive for an honest review of any kind is a material connection that must be clearly disclosed when the review is used. Many review sites add their own restrictions on incentives. Our article on requesting testimonials shows how to ask without creating these problems.

A disclosure should be clear and easy to notice, placed right next to the quote, in plain words such as "This customer received a discount for leaving a review".

If you sell in other markets, local rules also apply. The United Kingdom and the European Union both have consumer protection rules that address fake reviews and how businesses present reviews. The same principles carry over: real reviews only, no distortion, clear disclosure of connections and no misleading selection.

• The review is real and you can link to it
• The quote keeps the reviewer's words, with trims marked by an ellipsis
• The author is shown as published, with the source named
• Any material connection is disclosed next to the quote
• The result described is typical, or you disclose what is typical
• The quote still describes your current product
• The platform's terms allow the way you display it
• Your selection does not claim to be your full review history

Read more about placement in our guide to website testimonials.

TestimonialScraper collects public reviews only, through official APIs, public feeds, public pages that allow it and imports you are entitled to use. It never creates reviews, never rewrites them and marks any trim with an ellipsis. Every quote keeps its author as published and a link to the source, and you can hide any quote with one click. Read the details on our security page or see how it works.