For years, brands have leaned on consumer reviews as a cornerstone of their online sales strategy. Ratings drive clicks, reviews drive conversions, and social proof drives trust. But that ecosystem depends on something fragile: honesty. The Federal Trade Commission (FTC) has made clear it intends to protect that honesty, and in December 2025, it issued its first coordinated public warning action, signaling an increased enforcement focus.
On December 22, 2025, the FTC issued warning letters to ten companies over potential violations of its Consumer Review Rule, a regulation that became effective on October 21, 2024. While the companies were not publicly identified, the FTC released a template of the warning letter, offering every brand and retailer a preview of exactly what the agency is looking for.
What the Consumer Review Rule Prohibits
The Consumer Review Rule was finalized in August 2024 and prohibits a range of deceptive or unfair practices surrounding the use of consumer reviews and testimonials. At its core, the Rule targets conduct that distorts what consumers actually think about a product or service.
Prohibited practices under the Rule include creating, buying or distributing fake reviews—that is, reviews from individuals who did not actually use the product or whose experience has been misrepresented. The Rule also bars conditioning any form of compensation or incentive on a reviewer expressing a particular sentiment, whether positive or negative. Soliciting a five-star review in exchange for a discount, for example, is a violation regardless of whether the reviewer genuinely liked the product.
The Rule further prohibits insider reviews without adequate disclosure. If an employee, company officer, or immediate family member posts a review of the brand’s product, that relationship must be clearly and conspicuously disclosed. Similarly, the Rule bars what the FTC calls “company-controlled review websites,” platforms that present themselves as independent consumer forums but are actually operated or curated by the brand. Review suppression is also prohibited: brands cannot use selective display practices, gating mechanisms, or other tools to hide negative feedback and present an artificially rosy picture to the public.
The Warning Letters and What They Reveal
According to the FTC’s published template, the warning letters were triggered by a combination of consumer complaints and information the companies themselves had submitted. Examples of conduct flagged in the letters included compensating employees to solicit five-star reviews from friends and family and obtaining reviews from individuals who had never used the product.
Although the letters do not constitute formal findings of liability, they represent the agency’s first coordinated enforcement sweep under the Rule and carry a direct warning: continued noncompliance may result in federal lawsuits and substantial civil penalties of up to $53,088 per violation, a figure subject to further inflation adjustment. Critically, that penalty applies on a per-violation basis. For brands operating at scale, a single non-compliant campaign can generate hundreds of individual violations in short order.
Recipients were given five business days to confirm a plan to bring their practices into compliance, a timeline that underscores the seriousness with which the FTC is treating these issues.
What Brands Should Do Now
The FTC’s December enforcement sweep is widely understood as a signal that the agency is shifting from education to active enforcement. Industries that rely heavily on consumer reviews, like ecommerce, beauty and personal care, health and wellness, and technology. are squarely in the agency’s sights.
Brands should treat this moment as an occasion for a comprehensive audit of their review practices. That means examining how reviews are solicited, displayed, and moderated, and asking whether any step in that process is connected to an incentive that influences sentiment. It also means scrutinizing any third-party vendors that handle review outreach on the brand’s behalf. The FTC has indicated it will hold brands responsible for conduct by agents acting on their behalf, even if the brand disclaimed responsibility in a contract.
Incentive programs deserve particular attention. Offering a discount in exchange for a review is not automatically a violation, but conditioning that discount on a positive review, or using language that nudges the reviewer toward enthusiasm rather than honesty, crosses the line. Phrases such as, “Tell us how much you loved it” accompanying a coupon code should be revised.
Internal disclosure obligations also warrant a review. Employees and executives who discuss the brand’s products in any public forum should understand that their relationship to the company must be disclosed clearly and not buried in a bio or omitted because the post feels casual.
The Bottom Line
The FTC’s Consumer Review Rule represents a meaningful shift in the regulatory environment for online commerce. Brands that built their review ecosystems under older, less structured guidelines now face an agency that has codified specific prohibitions and demonstrated a willingness to act on them. For questions about how the Rule applies to your review practices, Terms of Service, influencer programs, or incentive structures, please contact KJK eCommerce attorney Kyle Stroup (KDS@kjk.com).