You can pay a customer to write a review. You cannot pay them to write a good one. That single distinction is what the FTC's Consumer Reviews and Testimonials Rule turns on — and it is also the point where most brands assume they are safe and are not, because the platforms where the review will actually appear are stricter than the law. Google prohibits review incentives outright. Trustpilot prohibits them and prohibits inviting only your happy customers. So the compliant answer is rarely "incentivize carefully"; it is "know which surface you are on".
This guide covers what the FTC rule actually prohibits, the sentiment-conditioning line that decides legality, where review gating sits, why platform policy is the tighter constraint, and how to design a reward program that survives both. This is general information, not legal advice — check your own program with counsel.
The rule, and what it actually says
The FTC's Rule on the Use of Consumer Reviews and Testimonials, codified at 16 CFR Part 465, took effect on 21 October 2024. It is a trade regulation rule, which means violations can carry civil penalties per violation — an amount the FTC adjusts annually for inflation and which now sits above 50,000 US dollars. That penalty exposure is the practical reason this rule changed behavior where a decade of FTC guidance had not.
The prohibitions that matter to a rewards program:
Fake or false reviews (§465.2). Creating, buying, selling, or disseminating reviews from people with no actual experience of the product. This explicitly reaches AI-generated reviews and reviews that misrepresent the reviewer's experience.
Incentivized reviews (§465.4). Providing compensation or other incentives conditioned on the review expressing a particular sentiment. The condition can be express or implied, and — this is the part that catches people — disclosing the incentive does not cure the violation.
Insider reviews (§465.5). Reviews by officers, managers, employees, agents, or their immediate relatives, without a clear and conspicuous disclosure of the relationship.
Company-controlled review sites (§465.6) and review suppression (§465.7), which covers using unfounded legal threats, intimidation, or false accusations to remove reviews, and misrepresenting a review section as complete when negative reviews have been pulled.
Fake social indicators (§465.8) — buying or selling followers, likes, and views that misrepresent influence.
The line that decides it: sentiment conditioning
Read §465.4 carefully and the boundary is narrow but clear. Offering "€10 back for reviewing your purchase" is not, on the face of the rule, prohibited. Offering "€10 back for a five-star review" is. So is "€10 back for a positive review", "review us and get a discount if you loved it", and anything that makes the reward contingent on tone.
Implied conditioning is still conditioning. If you only send the reward to people who left four or five stars, you have created the condition regardless of what the offer said. If your landing page shows five glowing example reviews next to the reward claim form, a regulator can reasonably read the message. The test is not the wording of the offer; it is whether the customer understood that a favorable review was the price of the reward.
The workable design is an incentive that is genuinely indifferent to the outcome: same reward for a one-star review as for a five-star one, granted on submission and never revoked, with the review left to say whatever the customer thinks.
Where review gating sits
Review gating — surveying customers first and inviting only the satisfied ones to post publicly — is widely described online as banned by the rule. That is not accurate, and the FTC's own guidance on the rule says as much: gating is not directly prohibited by Part 465 on its face.
That is a much smaller reassurance than it sounds. Gating can still be an unfair or deceptive practice under Section 5 of the FTC Act. If it goes further and becomes selective suppression of negative reviews you already have, it lands squarely inside §465.7. And, as below, the platform you are gating on may forbid it even where the law does not. "Not specifically named in Part 465" is a poor foundation for a review strategy.
The tighter constraint: platform policy
Here is what most compliance write-ups skip. Even if your incentive is perfectly sentiment-neutral and legal, the platform can still remove your reviews and penalize your listing.
Google. Google's contribution policies prohibit offering "incentives – such as payment, discounts, free goods and/or services – in exchange for posting any review or revision or removal of a negative review." There is no sentiment-neutral exemption. Content that has been "paid for, directly or in kind" is treated as fake engagement. Enforcement in 2026 has been visibly tightened, and consequences range from review removal to profile suspension. In practice: do not incentivize Google reviews at all.
Trustpilot. Businesses may invite customers to review, but must not offer incentives and must not invite only happy customers — Trustpilot bans gating explicitly, which the FTC rule does not.
Marketplaces run their own rules, and some operate sanctioned programs (Amazon's Vine being the well-known example) precisely because unsanctioned incentives are otherwise prohibited. Read the specific marketplace's policy; do not generalize from one to another.
The pattern is consistent: platform policy is the binding constraint on review incentives, and the law is the floor beneath it.
When incentivizing reviews is the wrong move entirely
If the reviews you need are on Google, or your category lives and dies on Trustpilot, the honest answer is that a review incentive program is not available to you and no amount of careful drafting fixes that. Reward the behavior you are allowed to reward instead: a video posted to the customer's own social profile, a referral, a repeat purchase. Those sit under advertising and endorsement rules — where disclosure makes the practice legitimate — rather than under review-platform policies that prohibit the incentive itself.
This is also the better commercial answer more often than people expect. A bought five-star average is a weak asset; it converts poorly against a 4.3 with substantive text, and it is fragile the moment a platform runs an enforcement sweep.
Designing a program that survives both layers
Decide the surface first, then the mechanic. Reward the act, never the sentiment, and put that in writing in the terms. Pay out identically regardless of rating, and keep the records that prove you did. Where a reward creates a material connection — a creator video, an affiliate post, an insider testimonial — disclose it clearly and inside the content itself, not in a bio or on a linked page. Never solicit reviews from employees or their families without disclosure. And never make removing or editing a negative review a condition of anything.
TikJoy's cashback rewards are built around public content on the customer's own channel rather than reviews on third-party platforms, which keeps the incentive on the side of the line where disclosure — not prohibition — is the governing rule. If you operate in a regulated category, our compliance overview sets out how the same principles interact with sector-specific advertising rules.