The reviews rule has teeth

How we work

Why that changes what an agency should offer

The Federal Trade Commission's rule on consumer reviews and testimonials draws clear lines. Creating or disseminating fake reviews is prohibited. Buying positive or negative reviews is prohibited. Reviews written by insiders — officers, employees, their close relatives — must be disclosed. Presenting a review site as independent while controlling it is prohibited. And suppressing or selectively withholding negative reviews so the overall impression misleads is prohibited. Contraventions can attract civil penalties.

What matters commercially is where the liability sits. An agency proposing any of these is not the party that ends up answering for it; the advertiser is. The same asymmetry runs through the endorsement guides, where a creator's missing disclosure is the advertiser's problem too, and through text messaging, where statutory damages under the TCPA are assessed per message and the plaintiff bar is extremely active. In each case the shortcut is offered by someone who does not carry its consequences.

So the refusals are the useful part of this page. We will not create, buy, solicit against a favourable rating, or suppress reviews. We will not buy followers or engagement, which also happen to destroy the only data that would tell you what was working. We will not publish an objective claim without the basis for it, and we will not send marketing texts to a list whose consent cannot be shown. That leaves a slower kind of marketing, reported honestly enough to include the months when nothing moved.