Incentivized reviews: what's allowed and what isn't

An incentivized review is a review someone wrote after you gave them something for it: a discount code, a free product, loyalty points, an entry in a prize draw. The rules look at two things: whether the reward was tied to a good rating, and whether the reader can tell it was there.

If you’re in the UK, your Act spells it incentivised, and I’ll use that spelling from here on.

This post covers three habits that sit close together: incentivised reviews, review gating (asking only the happy customers) and buying reviews outright. It goes through what the FTC’s rule, the UK’s DMCC Act and the EU’s Omnibus rule say, the cases so far, and what a shop can still do.

What counts as an incentivized review

The FTC’s Q&A on its Consumer Review Rule says an incentive is fine as long as there’s no express or implied requirement that the reviews have to express a particular sentiment. The FTC’s own example is a card that asks diners to share their visit and get a $5 coupon, worded so that a reader takes it to mean a positive review gets the coupon. You can hope for good reviews. You can’t make them the condition.

The rule itself, 16 CFR 465.4, covers compensation given in exchange for, or conditioned expressly or by implication on reviews expressing a particular sentiment, whether positive or negative. A disclosure doesn’t repair it. The Q&A says paying for five-star reviews is covered even when the reviewer says they were paid.

The UK draws the line in a different place. Schedule 20 of the Digital Markets, Competition and Consumers Act 2024 lists submitting, or commissioning someone to write, a consumer review that conceals the fact it has been incentivised as a practice that’s unfair in all circumstances. Rewarding a review is allowed. Concealing the reward is the banned part. The CMA’s short guide for businesses asks you to have a policy that states your approach to incentivised reviews.

The EU text doesn’t use the word at all, but the Danish Consumer Ombudsman applied the same thinking in 2016 when a travel agency offered a ski trip to whoever wrote the best review. The agency changed its wording, and the Ombudsman added that reviews written for a prize draw should say so.

Review gating: asking only the happy customers

Review gating is a form that asks “how was it?” and sends the five-star people to Google while the one-star people go to a private complaint box. It’s also a review tool that publishes four and five stars on its own and holds everything else for approval. Either way, the page shows a subset and looks like the whole.

The FTC’s Q&A is candid about the first version: the rule does not contain a specific prohibition against such conduct, and then it says the practice can still fall under the FTC Act. The FTC’s guide for marketers from January 2022 puts it as advice: Don’t ask for reviews only from customers you think will leave positive ones.

The second version is in the rule. Section 465.7(b) covers a business that misrepresents that the reviews on its page represent most or all of the reviews submitted when reviews were held back for their rating. Filtering that applies to every review the same way is allowed: abusive content, personal information, reviews that are clearly false, reviews about something else entirely.

The case the FTC still cites is Fashion Nova. On 25 January 2022 it announced a $4.2 million settlement over allegations that the retailer’s review tool posted four- and five-star reviews automatically and held lower-rated ones for approval. From late 2015 to November 2019, the FTC said, hundreds of thousands of those were never approved or posted. Samuel Levine, then head of the FTC’s consumer bureau, said: Deceptive review practices cheat consumers, undercut honest businesses, and pollute online commerce.

The UK has the same idea in paragraph 13(2) of Schedule 20: publishing reviews or review information in a misleading way, with selectively removing or prioritising negative or positive reviews as the example. On 27 March 2026 the CMA opened five investigations, one of them into whether one-star reviews moderated by Feefo were left off Autotrader’s platform and out of its star ratings. No finding has been made.

The visitor can’t see the filter, which is why review gating sits in the dark patterns post too.

Buying reviews: the cases so far

Paid reviews for a supplement

In February 2019 the FTC brought its first case over paid reviews on an independent retail site. It alleged that Cure Encapsulations and its owner paid a website, amazonverifiedreviews.com, to write and post Amazon reviews of a garcinia cambogia product. According to the complaint, the owner told the site’s operator the product needed an average of 4.3 stars to sell and asked that it stay a five star. The settlement carried a $12.8 million judgment, suspended on payment of $50,000 and some unpaid tax.

A free product for five stars

The TruHeight case is the one that maps onto the new rule. The FTC alleged that the supplement seller relied on reviews written by its own employees and vendors, and on reviews from customers offered a free product or a discount for a five-star rating. It also alleged fake social media profiles run by bots. The final order, approved in July 2026, bars the company from misrepresenting reviews and from buying reviews tied to a sentiment, with a $4 million judgment partly suspended once $750,000 is paid.

Snack boxes for good reviews

UrthBox goes back to 2019, and it’s the plainest example of an incentive with a rating attached. The FTC alleged that for most of 2017 the snack-box seller offered customers a free box for a positive review on the Better Business Bureau’s site, and store credit or free boxes for positive posts on social media. The $100,000 payment in that settlement was tied to a separate free-trial allegation. The FTC’s business blog drew one lesson from it, in five words: It’s unwise to incentivize consumer reviews.

Since the rule took effect, the FTC has started with letters. On 22 December 2025 its staff wrote to ten companies about possible problems under the rule, including incentives for five-star reviews. The letters aren’t findings. They do say what’s at stake: penalties of up to $53,088 each time the rule is knowingly broken.

The CMA’s March 2026 batch includes a case that reads like a small-business habit. It’s looking at whether Pasta Evangelists gave customers discounts on future orders for five-star reviews on delivery apps without saying so. The case page says no finding has been made, and the next update is due in the winter of 2026 to 2027.

In the Netherlands the ACM fined the webshop TrendX €100,000 in 2022 after finding that it posted fake positive reviews on its own site and didn’t publish the negative reviews real customers had written.

What the three rules say

The US Consumer Review Rule

16 CFR Part 465 took effect on 21 October 2024. The FTC’s announcement lists what it bans: fake reviews, including AI-generated ones; buying reviews with a sentiment attached; insider reviews without a clear note of the connection; review sites a company controls that pose as independent; suppressing reviews with threats or by hiding them for their rating; and buying fake followers or views.

The UK banned practice

Paragraph 13 of Schedule 20 to the DMCC Act has four parts: submitting or commissioning a fake or concealed incentivised review; publishing reviews in a misleading way; publishing reviews without reasonable and proportionate steps to prevent and remove the fake ones; and offering a service that helps anyone do the first two. A fake review is one that purports to be, but is not, based on a person’s genuine experience. The chapter came into force on 6 April 2025.

The EU Omnibus rule

Directive 2019/2161 has applied since 28 May 2022. It adds a line to the Unfair Commercial Practices Directive saying that, when a trader gives access to reviews, information about whether and how the trader ensures that the published reviews originate from consumers who have actually used or purchased the product is material. It also adds two items to the EU’s banned list: saying reviews come from real buyers without reasonable and proportionate steps to check, and submitting or commissioning false reviews or misrepresenting reviews to promote a product.

What you can still do

These habits sit inside all three rules:

• Ask everyone. The FTC’s Q&A says a general invitation sent to all customers is fine, even with an incentive offered to everyone who responds.
• Keep the reward flat. The same 10% for one star as for five, and no wording that hints at which one you’d prefer.
• Say the reward was there. A label on the review, and a line in your reviews policy. The FTC’s guide asks for the disclosure even when the reward wasn’t conditional.
• Show the low ones. Hold back a review for abuse, personal data or being off-topic, and apply that to every review the same way.
• Say how you check. One sentence on how you make sure reviews come from buyers covers the EU’s material-information point and the CMA’s reasonable-steps point. The CMA adds that assessing the risk is not a one-off exercise.
• Read the platform’s rules. The FTC notes that some platforms don’t allow rewarded reviews at all, disclosed or not.

A five-minute check of your own reviews page

On your phone, where most of your visitors read reviews:

1. Open your reviews page and sort by lowest rating. If nothing sits under four stars, work out where the lower ones went.
2. Open the last review request you sent. Does it go to everyone who bought, or only to people who first answered “happy” to a question?
3. Read the wording of any reward. “Leave a review and get 10% off” is flat. “Leave us five stars for 10% off” ties the reward to the rating.
4. Find a rewarded review on the page. Could a stranger tell it was rewarded without being told?
5. Look for a line on how reviews are checked, in the policy or under the reviews widget. If there isn’t one, write one.
6. If you show a star rating from a third-party platform, open that platform and compare the number and the count.

Peeky reads the public pages of your site. For reviews and testimonials, the checks are US-01, UK-13 and EU-11 in the Handbook.

Questions people ask

What does incentivized review mean?

It's a review someone wrote after being offered something for it: a discount, a free product, points or a prize entry. The FTC's rule allows the offer as long as there's no express or implied requirement that the review say something particular, and the FTC's guide asks you to disclose it.

Is review gating allowed?

Asking only the customers you expect to be happy isn't named in the FTC's rule, and its Q&A says so, but the FTC adds that the practice can still fall under the FTC Act. In the UK, publishing reviews in a misleading way, including selectively removing negative ones, is a banned practice.

Can I offer a discount for a review?

Yes, if the discount is the same whatever the rating. The US rule bars compensation conditioned expressly or by implication on a particular sentiment. Say the discount was offered, and check the platform's own rules first, because some don't allow rewarded reviews at all.

Do I have to say a review was incentivised?

In the UK, submitting or commissioning a review that conceals the fact it has been incentivised is on the banned list. The FTC's guide for marketers says to disclose an incentive even when it wasn't tied to a good review, because readers weigh a rewarded review differently.

What happened to companies that bought reviews?

Cure Encapsulations settled with the FTC in 2019 after allegedly paying a website for Amazon reviews, with a $12.8 million judgment suspended on payment of $50,000. TruHeight's final order in 2026 carried a $4 million judgment with $750,000 payable.