Is it legal to pay for reviews? What the rules allow and ban

You have a happy customer on the phone, a review page with four reviews on it, and a gift card in your drawer. Is it legal to pay for reviews, or to offer a discount for one? The short answer for a business in the US or the UK is that you may reward an honest review, you must make sure the reward is disclosed, and you may never pay for a positive one. The longer answer is below, with the rules quoted from the regulators' own texts rather than summarised, because the detail is where businesses get caught.

This post states the rules as published by the US Federal Trade Commission and the UK Competition and Markets Authority. It is not legal advice. If you are planning a campaign with money or goods attached, have a lawyer in your jurisdiction read it first.

Is it legal to pay for reviews? The three lines the rules draw

Both the US and the UK rules sort what a business does into the same three bins:

1. Asking for honest reviews, with or without a reward, is allowed.
2. Hiding the reward is not. A review that was paid for, discounted or gifted has to say so.
3. Buying the sentiment is not. A reward that only arrives for five stars, or a review by someone who never used the product, is banned outright.

What changed in 2024 is that the US turned the bans into a rule with civil penalties, and the UK made fake and concealed incentivised reviews a banned practice in primary legislation. Many of the guides still circulating were written before either happened, so check the date on anything you read.

The US rule: what the FTC banned in 2024

On 14 August 2024 the FTC announced its final Rule on the Use of Consumer Reviews and Testimonials (16 CFR Part 465), adopted on a 5-0 vote and effective "60 days after the date it's published in the Federal Register". The FTC's announcement lists what the rule prohibits. The parts that touch a business thinking about paying for reviews, in the FTC's words:

• Reviews and testimonials "that misrepresent that they are by someone who does not exist, such as AI-generated fake reviews", or that misrepresent actual experience of the product.
• "providing compensation or other incentives conditioned on the writing of consumer reviews expressing a particular sentiment, either positive or negative."
• "certain reviews and testimonials written by company insiders that fail to clearly and conspicuously disclose the giver's material connection to the business."
• "misrepresenting that a website or entity it controls provides independent reviews."
• "using unfounded or groundless legal threats, physical threats, intimidation" to get negative reviews removed.
• "selling or buying fake indicators of social media influence, such as followers or views generated by a bot."

The announcement also says the rule "will enhance deterrence and strengthen FTC enforcement actions" by letting the agency "seek civil penalties against knowing violators".

Read the second bullet twice. It does not ban paying for reviews. It bans paying for reviews conditioned on a sentiment. A gift card for any honest review is on one side of that line; a gift card for a five-star review is on the other.

What you may offer, and the condition that keeps it legal

The FTC's Endorsement Guides FAQ answers the question most owners actually ask, almost word for word: a new business with no advertising budget wants to tell people that if they say good things about it on a third-party review platform, they get a discount. The FTC's answer is "No", because "Endorsements must reflect the honest opinions or experiences of the endorser" and "you can't condition an incentive" such as a discount "on a review being positive, as that may motivate people to give a positive review for reasons unrelated to their honest opinion about your product."

The same answer says what you may do instead: invite customers to post honest reviews, positive or negative, after they have used the product, and, if you offer an incentive, tell them in advance that they should disclose what they received and that "they won't get the discount unless they do so". So the reward follows the disclosure, not the review.

It then adds a warning that a disclosure does not cure. If offering an incentive "materially increases your average star rating", you "may still be engaging in a deceptive practice, despite the disclosures". A disclosed reward for any honest review is the lawful shape, but it is not a free pass: if the rewarded reviews run visibly higher than the unrewarded ones, the FTC's view is that the incentive itself may be deceiving readers.

Two more answers from the same FAQ bear on how you run it:

• A reviewer who gets a free product needs a disclosure however they got it: "It doesn't matter whether the company gives you a code, ships it directly to you, gives you money to buy it yourself, or reimburses you after you buy it."
• An employee who reviews their employer's product "definitely should disclose" the employment relationship, because readers "probably won't know who you are or where you work."

Here is the practical version. Nothing in this table is a legal opinion; each cell points at the quoted passage above or below it.

The UK rule: the DMCC Act 2024 and the CMA's guidance

The UK put reviews into the list of banned practices in the Digital Markets, Competition and Consumers Act 2024 (paragraph 13 of Schedule 20), and the Competition and Markets Authority published its guidance on the prohibition (CMA208) on 4 April 2025. Paragraph 1.1 describes it as behaviour "that is automatically unfair and illegal", covering "fake reviews, concealed incentivised reviews", and requiring traders "not to publish consumer reviews (and information derived from them) in a misleading way".

On the question in the title, the guidance is plainer than most blog posts about it. Paragraph 3.7:

Traders may want to incentivise customers to leave a review for example by paying them, offering them future discounts or free products. Traders are free to do this but to comply with the law they must: (a) tell consumers that the review has been incentivised, and (b) the review must still reflect the reviewer's genuine experience.

Three details from the surrounding paragraphs change how you run that in practice:

• A discount counts as payment. Paragraph 2.10 says commissioning "is not limited to making monetary payments" and lists "money", "commissions", "discounts or vouchers", and "leases or loans free of charge or on more favourable terms". So "is it legal to give discounts for reviews?" has the same answer as cash: yes, disclosed, for an honest review.
• The disclosure has to be visible. Paragraph 2.9 says a review conceals its incentive when the commissioning "is not made apparent (whether through the contents of the review or otherwise)", including "missing, obscure or hidden disclosure". Paragraph 3.5 adds that usually the reviewer must "label the review prominently as incentivised, namely, as an advert", and the label "should not have an ambiguous meaning or be placed where it might not be seen."
• The platform's rule still applies. Paragraph 3.4: "many publication media (for example, websites, platforms etc.) do not allow incentivised reviews. Where this is the case, submitting an incentivised review is likely to be misleading."

That last point is the one that catches businesses that have read the law and nothing else.

Is it legal to pay for Google reviews? Read the platform's policy first

The law says a disclosed reward for an honest review is lawful. It does not oblige any platform to accept one. Google, Yelp, Amazon and Trustpilot each publish a review policy of their own, and the CMA's paragraph 3.4 above says what happens on a platform whose policy forbids incentives: submitting one there "is likely to be misleading", and the operator "may also take appropriate steps to prevent their publication and remove them."

So the order of checking is the reverse of what most owners do. Read the policy of the platform you want the reviews on before you decide what to offer. If it bans incentives, the question "is it legal to pay for Google reviews" (or Yelp, or Amazon) has a practical answer that does not depend on the statute: do not, because the reviews may be removed and, in the CMA's words, the attempt is likely to be misleading. If the platform allows disclosed incentives, the law's conditions above apply on top of the platform's own.

Review gating: asking only your happy customers

Review gating is the practice of asking a customer how they felt first, then sending the review link only to those who answered well. It is popular because it works in the short term, and most guides do not give it a section of its own.

The FTC's FAQ addresses it through an example: a company that wants to send a review link to customers in the regions where satisfaction is highest and not to the regions where it is poor. The answer is "No", because "Only asking for reviews from customers who you think are more likely to be happy with your product would be misleading if it substantially skews the favorability of the reviews." Note the condition: the test is whether the resulting picture is skewed, not whether a filter existed. A business that asks everyone and happens to have happy customers is fine.

In its paragraphs on asking for reviews, the CMA's guidance describes lawful asking as "merely emailing customers generally to ask if they wish to provide a review" and does not address selective asking directly. Paragraph 1.1 bans traders from "publish[ing] consumer reviews (and information derived from them) in a misleading way", which is a rule about the reviews a business publishes, not about who it emails first; whether a filtered invitation list falls under it is not something the paragraphs on asking answer, so treat the FTC's "No" as the standard to follow until a UK source says otherwise.

The safe practice is also the useful one. Ask every customer, and route the unhappy ones to a support conversation as well, not instead. Review tools have a row for the private half: the reputation and review management listing judges every product on "private negative feedback capture". Whatever the tool does, the public invitation goes to everyone.

A review request you can send: before and after

A message a shop owner might draft, and the version that keeps both rules. The reward is illustrative.

Before (breaks the rules in both countries):

Loved your new desk? Leave us a 5-star review and we'll send you a 10 percent code for your next order.

The reward is conditioned on the sentiment, there is no disclosure instruction, and the platform's policy was not checked.

After (a disclosed reward for an honest review, on a platform that allows it):

Thanks for your order. We would value your honest review, good or bad, on [platform]. Everyone who posts one gets a 10 percent code for their next order, whatever rating they give. Platform rules and consumer law require your review to say you received a reward, so please include a line such as "I received a discount for leaving this review." We send the code once we see a review with that line; without it, there is no code.

The after version asks for honesty in so many words, says the reward is the same for any rating, tells the reviewer in advance to disclose and that no disclosure means no reward (the FTC's conditions), and tells them how (the CMA's "prominently" condition). It still only works on a platform whose policy allows disclosed incentives, and that is on you to check.

The five steps, in the order that keeps you out of trouble

1. Read the platform's policy first. If it bans incentives, stop here and ask for unrewarded honest reviews instead.
2. Offer the same reward for any honest review. Write "whatever rating you give" into the message. Never tier it by stars.
3. Tell the reviewer in advance to disclose it, and give them the wording.
4. Send the reward only once the review carries the disclosure. Say so up front: the FTC's wording is that they won't get the discount unless they disclose. In the UK the duty sits with you as well as the reviewer: paragraph 3.7 says traders must "tell consumers that the review has been incentivised", and the guidance's page 11 commissioning examples include a trader who does not make clear to the reviewer that the incentive must be disclosed.
5. Keep the records: the message you sent, the policy you read and the date, and a list of who received what. If a regulator or a platform asks, this is what shows the incentive was never conditioned on sentiment.

What this will not do is rescue a product people dislike, and it can backfire in a way the disclosure does not fix: the FTC's FAQ says an incentive that "materially increases your average star rating" may be deceptive "despite the disclosures", so compare the average of rewarded and unrewarded reviews and stop the offer if the gap is visible. A page of labelled "I received a discount" reviews also reads differently to a buyer than a page of unprompted ones. Budget for the discount codes too: a 10 percent code on a hundred orders is a real cost against a handful of extra reviews.

What to do this week

Pick the one platform where your next customer will look for you, read its review policy, and decide from that whether you are running an incentive at all. Then send every customer the same honest-review request, rewarded or not, and keep a copy. If you want software to send the requests and capture complaints privately, compare the tools on the reputation and review management listing, or start from the software categories index.