On December 22, 2025, the FTC announced that it had sent letters to ten companies warning them of potential violations of the agency’s Consumer Review Rule. Based on the template letter the FTC released, the letters remind recipients that the Rule generally makes it unlawful for a company to:
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Use reviews or testimonials that misrepresent a reviewer’s experience with a product or service.
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Provide incentives that are conditioned on a reviewer expressing a particular sentiment;
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Use reviews or testimonials from insiders without clearly disclosing their relationship to the company;
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Misrepresent that a website or entity it controls provides independent reviews about a category of products or services the company sells;
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Suppress negative reviews; and
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Buy or sell fake indicators of social media influence, such as followers or views generated by a bot.
The template letter also includes a placeholder for FTC staff to list specific allegations about the recipient. Those allegations are based on consumer complaints the FTC received and information provided by the companies.
Although the FTC hasn’t determined that the recipients violated the Rule, the letters put them on notice that violations can result in a federal lawsuit and civil penalties of up to $53,088 per violation. Recipients have five days to respond.
For more details on the scope of the Rule and how companies can comply, see our posts here and here.
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