Can you offer incentives for Google reviews? What the FTC says

You have probably already printed the cards: ten per cent off the next visit for anyone who leaves a Google review. Now you are not sure whether you have done something you should not have.

The direct answer, and it is not legal advice: the FTC's rule does not ban incentives. It bans incentives conditioned, expressly or by implication, on a review expressing a particular sentiment. Google's policy is a separate instrument and it is stricter — it bans incentives offered in exchange for any review at all. That gap is the whole point. A business can be entirely inside the FTC rule and still lose every review it bought with a voucher.

Both sources are quoted below so you can read them yourself.

The short answer

Two instruments apply. They are enforced by different people, and they do not say the same thing.

Read the third column twice. The FTC row is conditioned on sentiment. The Google row is conditioned on the act. That single difference decides three of the four situations below, and it is why a voucher scheme can sit inside one rulebook and outside the other.

What the FTC rule actually says

The sentence that matters

The rule is the Trade Regulation Rule on the Use of Consumer Reviews and Testimonials, 16 CFR Part 465, in force since 21 October 2024 6. The incentives provision is § 465.4, headed "Buying Positive or Negative Consumer Reviews". It is one sentence, and the operative words are these: "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" 1. The sentence opens by calling that an unfair or deceptive act or practice and a violation of the part, and it closes by tying the review to the product, service or business in question.

Three phrases do the work. *Conditioned* is the first: the violation is the condition, not the payment. *Expressly or by implication* is the second: you do not have to write the condition down for it to exist. *Whether positive or negative* is the third, and it makes the rule symmetrical — paying for a good review and paying for a bad one are the same problem.

The FTC's own examples of an implied condition are ordinary marketing sentences, not contracts. A steakhouse offering a $5 coupon to anyone who says how much they loved their visit, or an arcade offering prize-draw entries to customers who tell their friends what fun they had, is implying that the review has to be positive 7.

What the rule does not say

The FTC answers the general question in its own words: "The rule does not prohibit giving incentives for reviews, as long as there isn't an express or implied requirement that the reviews have to express a particular sentiment." 8

That is narrower than it sounds, so be precise about what the text covers. It does not reach asking for reviews. It does not reach a benefit given to every customer whether or not they review, because nothing in that arrangement is conditioned on a review at all. The FTC has published no guidance on that second case; the nearest thing in its Q&A is a different question, about offering an incentive to all recipients who do post a review 9.

One correction to the shorthand you will see repeated. The § 465.4 prohibition is sentiment-conditioned, but the rule does not leave the act of paying for a review untouched. § 465.1(m) defines purchasing a review as giving something of value in exchange for one, and it names discounts, coupons and contest entries among the forms that value can take 10. § 465.2(b) separately prohibits buying a review the business knew or should have known was fake or false 10. The act is inside the rule's vocabulary. It bites there only where the purchased review is fake or false.

Who enforces it, and what it costs

The FTC enforces the rule by filing in federal court, and courts can impose civil penalties for knowing violations 6. As of October 2026, up to $53,088 per violation 2. That figure has been current since 17 January 2025 and is still current, because the 2026 inflation adjustment was cancelled 11. It is a ceiling for knowing violations, not a price list, and it is not multiplied by the number of reviews you collected.

There is no private right of action under the rule 3. A competitor cannot sue you under it.

What Google's policy says - and why it is the one that will bite you first

The policy wording

The wording sits on Google's "Prohibited & restricted content" page, under "Fake & Misleading Content & Behavior", in the fake engagement block. Read on 26 October 2026. The page lists what merchants and users may not do, and the incentives bullet reads: "Offer incentives – such as payment, discounts, free goods and/or services - in exchange for posting any review or revision or removal of a negative review" 4.

Any review. Not a positive review. Not a five-star review. Any review. Google also lists the resulting review as prohibited content in its own right: content posted because a business offered an incentive 4. Removal is not limited to the offer; the reviews themselves are eligible. For the wider set of behaviours the same page prohibits, see what Google's policy covers.

What enforcement actually looks like

Google says that where it finds a business owner has broken its Fake Engagement policy, it may place restrictions on the Business Profile as well as removing the reviews 5.

The page gives three examples: the profile cannot collect new reviews or ratings for a set period; its existing reviews and ratings are hidden for a set period; or the profile carries a warning telling customers that fake reviews were removed 12. Note the hedging. Google says it "might" act, and it calls the list examples rather than a complete set. It commits to nothing.

What Google does not document matters as much. Google's restrictions page documents no monetary penalty, no suspension of the business, and no consequence for the owner's personal Google account. Do not assume one. There is an appeal route: Google says businesses can appeal, and that it will re-review the profile and any context supplied with the appeal 5.

Anyone can report a review, a competitor included, and Google's test is policy compliance rather than the motive behind the report. Google's help page says any review can be reported, but only reviews that break its policies are eligible for removal 13.

Why the platform rule matters more day to day

The FTC has to build a case and go to court. Google removes a review and restricts a profile on its own judgement, and it needs nobody's permission.

The FTC has not announced an enforcement action about review incentives since the rule took effect. In December 2025 its staff sent warning letters to 10 companies, and the FTC says those letters are not findings that anyone broke the rule 14. That is the whole of the federal record announced in public. The platform side runs continuously.

The four things owners actually mean by 'incentive'

1. A discount for anyone who leaves a review

This is the card in your hand: 10% off the next visit, for anyone, whatever they write. Nothing is conditioned on sentiment, so § 465.4 does not reach it. The rule's definition of purchasing a review does name discounts and coupons among the forms of value it covers 10, and § 465.2(b) bites if the review you bought turns out to be fake or false — but the sentiment prohibition is not the instrument that catches this.

Google's policy is. The bullet above covers a discount for anyone who reviews, exactly as written 4. This is the clearest place the two rulebooks part company, and it is the case most small businesses are actually in.

The FTC's Endorsement Guides add a separate duty: where an incentive is not conditioned on sentiment, the resulting review needs a clear and conspicuous disclosure of the incentive 15. Disclosure does not make the arrangement acceptable to Google. It answers a different question.

A discount for every customer, with reviews mentioned in the email, is a third arrangement again: nothing is conditioned on a review, so § 465.4 does not reach it. On the face of Google's wording, an unconditional discount is not offered in exchange for a review either — but Google has not said so, and silence is not a place to stand.

2. A discount for a five-star review

This is the one case where the two rulebooks agree, and it is worth saying plainly because it makes the other three sections credible.

§ 465.4 names it. Google's policy covers it twice: the offer is prohibited, and the resulting review is prohibited content in its own right 4.

The FTC also closes the workaround people reach for first. Asked whether a business can pay for five-star reviews on third-party platforms so long as the reviewers add a disclosure about the incentive, the FTC's answer is no, and it says that conduct would violate § 465.4 16. A disclosure does not cure a sentiment condition.

There is a related distinction to hold on to. Expecting a positive review is not the same as requiring one — but the FTC adds that the practice may still breach the FTC Act 17. The rule and the Act are not the same instrument.

3. A prize draw open to everyone who was asked, review or not

This is the genuinely unsettled one, and it is unsettled in a direction that should make you cautious rather than comfortable.

If the draw is genuinely open to everyone who was asked, with no review required, that is the arrangement the rule text does not reach — nothing is conditioned on a review. But two things in the FTC's material cut against treating it as settled. The definition of purchasing a review names contest entries among the forms of value it covers 10. And the only prize-draw example the FTC gives is one it treats as implying a positivity requirement — the arcade example above 7.

What is not addressed is a draw open to everyone asked, review or not. The FTC has published no guidance on it, and the rule text does not resolve it. That is where the text stops, and it is where to take advice rather than guess.

One duty does still attach. The Endorsement Guides treat the chance of winning a prize as a material connection, alongside payment and media appearances 18. If a review results from an incentivised arrangement, the connection needs disclosing.

4. A staff bonus tied to the star average

This is not an incentive problem at all. It is an insider-review problem, and the failure mode is worse: pressure on staff produces reviews that are not from customers.

The rule governs insider reviews separately. § 465.5 requires clear and conspicuous disclosure of the relationship, and § 465.2(c) covers procuring reviews from officers, managers, employees or their immediate relatives 10. Google's page names staff review targets as an example of what it bans 19.

The FTC's warning here is the part most owners have not heard. Insider reviews that materially raise an average star rating can breach the FTC Act even with disclosure, "because consumers might see only the star rating" and never open the individual reviews 8. Disclosure is not a fix when the reviews are not from customers. For what that looks like from the outside, see what Google's policy covers.

Where the pages you have already read contradict each other

Why both readings exist

You have probably found two pages that disagree. One states flatly that incentivising reviews is against the law in the United States. Another, from the same publisher, says businesses can offer incentives to customers who leave reviews. Both are written with confidence. Neither is lying.

The flat claim collapses two instruments into one. Read Google's "any review" wording as though it were the law and every incentive is unlawful. Read § 465.4 as though it were the whole picture and incentives are fine provided the sentiment is not conditioned. Each page describes one instrument and implies it is the only one.

The same fact reads differently under each. A voucher for anyone who reviews is outside § 465.4 and inside Google's policy. A voucher for a five-star review is inside both. A prize draw open to everyone asked is addressed by neither with any clarity. Separate the instruments and the contradiction stops being a contradiction; it becomes a description of two rulebooks.

That is not a criticism of those pages. It is what happens when a question with two answers gets answered once.

How to check this yourself in five minutes

Two links, and one thing to look for on each.

The rule text is at ecfr.gov/current/title-16/section-465.4. It is one sentence. Look for "conditioned expressly or by implication on" and "whether positive or negative". If the sentence you are reading does not contain those words, it is not the rule.

Google's page is at support.google.com/business/answer/7400114. Under "Fake & Misleading Content & Behavior", find "We do not allow merchants or users to" and read the incentives bullet. Look for "any review". That word is the difference.

What to do instead

Ask everyone, at the moment the experience is fresh

The ask is not the problem. The condition is. Google's page expressly allows merchants to ask for reviews of a genuine experience, provided they offer no incentive and make no attempt to steer the rating or the content 20.

So ask every customer, not the ones you think are happy. Selective solicitation is a separate question with its own answer: the rule contains no specific prohibition, but the FTC says the practice may still breach the FTC Act 21. Asking everyone removes the question. There is more on the wording in a note on asking for reviews.

Make asking take ten seconds

A direct review link, a QR code at the counter, one follow-up and then stop. The shorter the path from the receipt to the review box, the more reviews you collect without paying for any of them.

Two limits come from Google's page. Do not require or pressure customers to leave a rating or write a review while on the premises, and do not request that specific content be included 4. A QR code on the counter is fine. Standing over the table while they type is not.

Reply to what you get

Replying is the part you control, and it costs nothing but attention. It also gives you something an incentive cannot: a public record that you answer the bad ones as well as the good.

Do not treat replies as a ranking lever. Whether reply rate affects local ranking is a separate question with its own evidence, and it is not settled here. What is settled is that a reply is the only thing you can do about a review you did not want. The approach is set out in what about refunds and compensation.

If you have already run an incentive

Stop conditioning anything on sentiment. That is the one change that moves you out of § 465.4.

Do not delete reviews, and do not ask staff to reword them. Paying a customer to change or remove a review is not prohibited by the rule, but the FTC says it may breach the FTC Act as an unfair or deceptive practice 22. Editing a review to look compliant creates a second problem on top of the first.

If Google has already restricted the profile, use the appeal route 5. If the amount at stake is large, or a platform has already acted, that is a conversation for a lawyer, not a blog post.

If you want to see your profile the way a customer sees it before you change anything, Run a free review audit.

If you are outside the US

The UK has a third shape, and it is neither of the two above. The Digital Markets, Competition and Consumers Act 2024, Schedule 20, paragraph 13, in force since 6 April 2025 23, covers submitting — or commissioning someone else to submit or write — a fake consumer review, or a consumer review that hides that it was incentivised 24.

The definition does the work: a review conceals the incentive where someone was commissioned to write or submit it and "that fact is not made apparent", whether through the review's contents or otherwise 25. The Competition and Markets Authority's guidance for businesses describes the same thing as reviews that conceal that they were written in exchange for money or other benefits 26.

So the UK does not ban incentivised reviews. It bans concealed ones. The fix there is disclosure — neither the FTC's answer (do not condition on sentiment) nor Google's (do not incentivise at all). If you operate in the UK, that is a third standard to meet, not a variation on the other two.

What this article is not

It is not legal advice. It reports what two instruments say, quotes both, and leaves the application to your facts.

The FTC says the same about its own guidance, which is the most useful point here: it is staff guidance, it is neither definitive nor comprehensive, it offers no safe harbour from liability, and the answers to some questions depend on the context and the specific facts 8.

If the amount at stake is large, or a platform has already acted against your profile, ask a lawyer. Reading the rule is a good start. It is not the same as advice about your situation.

Sources

Primary sources only. Each was read on 26 October 2026.

• 16 CFR § 465.4, Buying Positive or Negative Consumer Reviews — source
• 16 CFR Part 465, Rule on the Use of Consumer Reviews and Testimonials, incl. § 465.1(m), § 465.2(b), § 465.2(c), § 465.5 — source
• 16 CFR § 255.5, Endorsement Guides — source
• The Consumer Reviews and Testimonials Rule: Questions and Answers, FTC — source
• Adjustments to Civil Penalty Amounts, 90 FR 5580 — source
• Civil Penalty Inflation Adjustments, 91 FR 58446 — source
• FTC Warns 10 Companies About Possible Violations of the Agency's New Consumer Review Rule, 22 December 2025 — source
• Prohibited & restricted content, Google — source
• Business Profile restrictions for policy violations, Google — source
• Report inappropriate reviews on your Business Profile, Google — source
• Digital Markets, Competition and Consumers Act 2024, Schedule 20, paragraph 13 — source
• DMCC Act 2024 (Commencement No. 2) Regulations 2025, regulation 2 — source
• Short guide for businesses: publishing consumer reviews and complying with consumer protection law (CMA208), CMA — source