Skip to main content

The Key to Honest Online Reviews

The Federal Trade Commission published two new guidelines around online reviews: it all comes down to transparency

Online reviews are here to stay. According to Forbes, 82 percent of U.S. consumers read online reviews before buying a new product and more than 63 percent indicate that they are more likely to buy from a site that has reviews or testimonials. Consumers read online reviews prior to making most purchases, but they are especially likely to mull over reviews for costly products or services, such as windows and doors. 

As the reliance on online reviews continues to grow, the Federal Trade Commission (FTC) has taken notice. In January 2022, the FTC published two new guidelines aimed at marketers who post online reviews. The guidelines include many tips about the proper way to vet and publish online reviews, but it all comes down to transparency. 

Put processes in place

The first guideline is Featuring Online Customer Reviews: A Guide for Platforms. In short, it advises companies that have a website or other platform where online reviews can be posted to have processes in place that ensure the reviews are from real users and accurately reflect the users’ actual experience with the product or service. 

The FTC’s platform guidance is the same whether the review process is “open,” meaning anyone can submit reviews, or “closed,” meaning reviews are limited to verified buyers or users. Companies are warned against only asking for positive reviews and discouraging consumers from leaving negative reviews. 

Additionally, if a company incentivizes consumers to leave a review, receipt of the incentive cannot be conditioned on the review being positive. Despite that, because of a perceived bias in accepting an incentive for a review, the FTC reports that some online platforms do not permit incentivized reviews while others label the reviews to state that the reviewer received an incentive.

The FTC guideline also addresses the effort of some marketers who look through reviews in an effort to remove fake reviews or those that violate company policies (e.g., harassing or discriminatory reviews). This review process is done by individuals or by automated systems and can occur before or after the reviews are posted online. 

No matter the system, the FTC recommends formalizing processes to identify fake, deceptive or manipulated reviews. It also advises against editing reviews to change the point of the review and cautions that positive and negative reviews should be treated equally and with the same scrutiny. Because technology is ever-changing, companies should also regularly examine and update the processes used.

How to actively seek reviews

The second guideline, Soliciting and Paying for Online Reviews: A Guide for Marketers, is directed at companies that actively seek reviews, either by themselves or through third-party marketing agencies. The FTC advises that if reviews will be posted on a platform or website other than your own, make sure you understand that company’s rules for reviews before you engage their services. 

If solicited or incentivized reviews are permitted, the FTC suggests refraining from asking for reviews from consumers who have not used the product or service. It also warns against asking staff, family or friends to write a review, unless the relationship and request is disclosed with the review. 

The FTC warns against working with third-party marketing companies that operate in a deceptive manner. For instance, comparison websites may say they offer unbiased reviews, but actually offer better ratings, reviews and placement to companies that pay for it. This practice must be avoided. Another red flag is a review platform that collects customer reviews to increase a company’s reputation and visibility but does not disclose to the public its relationship with the company. 

Search engine optimization and reputation management companies that claim to be able to boost customer ratings should be vetted to make sure they are not boosting reviews by publishing fake reviews, whether positive reviews on your site or negative reviews on a competitor’s site.

If you work with companies that post your reviews or solicit reviews on your behalf, make sure those companies are working above board to obtain and publish honest reviews. Publishing deceptive or fake reviews is a disservice not only to consumers, but also to your company. 

The bottom line

The key takeaway from the FTC guidelines is to make sure reviews are displayed in a transparent manner. This can be accomplished by:

  • Publishing all real reviews, whether they are good or bad
  • Refraining from displaying reviews in a misleading manner, such as placing the best ones up front
  • Having processes to identify fake reviews
  • Clearly and conspicuously disclosing if the reviewer received an incentive for leaving a review
  • Clearly disclosing the processes used for collecting, processing and displaying reviews
  • Being honest about how you obtain and display reviews

Transparency is the key. 


Susan MacKay

Susan MacKay

Susan MacKay is an attorney with The Gary Law Group, a law firm based in Portland, Ore., that focuses on legal issues facing manufacturers of windows and doors. She can be reached at 503/620-6615 or