#What the FTC's fake reviews rule prohibits
Four practices sit at the center of the rule: reviews for products or experiences the reviewer never had, reviews written or purchased to appear independent when they are not, suppressing negative reviews while soliciting or amplifying only positive ones, and offering a reviewer compensation without disclosing that the review was incentivized.
Review gating is the practice most relevant to a dealership's existing habits: a process that asks a customer how their visit went before deciding whether to invite them to leave a public review, sending only the satisfied ones to Google or a review platform and routing the unhappy ones to a private feedback form instead. That selective routing is the specific practice the rule targets, independent of whether any individual review is itself fake.
#Where dealership reviews sit close to the FTC's fake reviews rule
A checkout or delivery process that includes an internal satisfaction question before deciding whether to send a public review invitation is the clearest fact pattern the rule addresses. If the answer to that internal question determines whether the customer sees a review request at all, that is review gating regardless of how the internal question is framed.
A staff incentive tied to review volume or review star rating can also create pressure that shades into the prohibited practices indirectly, even where no individual review is fabricated, because it creates an incentive to gate or to solicit selectively. Training matters here as much as legal review does.
An incentive alone is not the violation, and by itself a discount or drawing entry offered for a review is not prohibited. What the rule requires is that the review disclose the incentive. A programme that offers the incentive without building in that disclosure is the version that carries exposure.
TABLE
Where a review-request programme commonly sits, and where it does not
This is a description of the rule's stated targets, not a compliance audit of any specific programme.
| Practice | The rule's position |
|---|---|
| Asking every customer for a review, the same way, regardless of how the visit went | Not gating; consistent with the rule |
| Asking about satisfaction first, then deciding whether to send a review request | Review gating, specifically prohibited |
| Offering a discount for a review, with the incentive disclosed in the review | Permitted with disclosure |
| Offering a discount for a review, with no disclosure requirement built in | The undisclosed-incentive practice the rule prohibits |
| A staff bonus tied to overall review volume, with no selective routing | Not directly addressed, but worth reviewing for indirect pressure |
Compiled 2026-09-13 from the FTC's published rule and enforcement commentary; not legal advice for a specific programme.
The broader review process this rule intersects with is covered on the dealership reviews hub, including how to structure a request process that asks everyone the same way.