The fake review rule is final. What it forbids.

Last week the Federal Trade Commission finalized its rule on fake reviews and testimonials. It takes effect on 21 October, and unlike most guidance about reviews, this one comes with the ability to seek civil penalties for each violation.

Most of the businesses we work with are not buying reviews from a website, so the first reaction has been that none of this applies. Read the rule and it does apply, because the parts that catch ordinary local businesses are the parts nobody thinks of as fake: the team member who left five stars in the first month, the raffle for anyone who reviews, the testimonial page that was written by the person who built the site.

Here is what it forbids and what we are cleaning up between now and October.

What the rule actually bans

In plain terms:

• Fake reviews and testimonials. Reviews written by people who do not exist, or by people who never used the business, or by real customers misrepresenting their experience. Writing them, buying them, selling them and publishing them are all covered when you know or should know what they are.
• Paying for a sentiment. You cannot offer money, a discount, a gift card or an entry in a drawing in exchange for a review that is positive. The problem is not the incentive on its own, it is conditioning it on the review saying something good.
• Insider reviews without disclosure. Reviews and testimonials from owners, managers, employees or their immediate families need the relationship disclosed clearly. Managers also may not ask employees for reviews without telling them the disclosure rules, and may not put undisclosed insider reviews out into the world.
• Company-controlled review sites dressed up as independent. A “best dentists in town” page owned by the practice, presented as a neutral review site.
• Suppressing negative reviews with threats. Unfounded legal threats, intimidation or false accusations used to get a review pulled. Also claiming that the reviews you display represent all or most reviews when the bad ones have been filtered out.
• Fake social proof. Buying followers, views or engagement to misrepresent influence for commercial purposes.

The three places local businesses are actually exposed

The launch reviews. Almost every practice and shop we have taken over has a handful of early five-star reviews from staff, spouses and the owner’s brother. They were written years ago, in good faith, to get the listing off zero. From 21 October they are undisclosed insider reviews. Take them down now, while doing so is housekeeping rather than a response to a complaint.

Contests and incentives. The version that gets businesses in trouble is not the gift card, it is the wording. “Leave us a five star review and be entered to win” conditions the prize on the sentiment, and it is also already against Google’s own policies, which prohibit incentivized reviews outright. The safe pattern has not changed in years: ask everybody, ask well, incentivize nothing.

The testimonials on your own website. This is where dental and medical sites tend to be weakest. Composite patients, quotes assembled from things a few people said, stock photography next to a first name and an initial, a testimonial borrowed from another location in the group. All of that is a testimonial that misrepresents a real experience. Practices also have the state board advertising rules and written patient consent to satisfy on top of the federal rule, so a testimonial page is the one part of a site we would rather rebuild from scratch than patch.

Suppression, and the widget on your homepage

Two habits deserve a closer look before October.

The first is review gating: asking happy customers for a public review and routing unhappy ones to a private feedback form. It has been against Google’s policies for a long time, and we stopped building it years ago. The rule is aimed at harder behavior, threats and intimidation, but the direction of travel is obvious. Send the same request to everyone.

The second is the review widget. Plenty of local sites run a slider that shows only the four and five star reviews under a heading like “what our patients say”. If the presentation implies that is the whole picture, you are on the wrong side of the suppression language. Two fixes work: pull the feed live and unfiltered, or clearly label the section as selected reviews with a link to the full profile.

A lawyer’s letter to a reviewer is the other one to retire. If a review is genuinely defamatory or was never a customer, report it through the platform and document it. A threatening letter to a patient who waited forty minutes is now a risk on top of being a bad idea.

What we are telling clients this month

• Read your Google, Yelp and Facebook profiles as a stranger would, and find any review left by someone who works for you or is related to you. Ask them to remove it.
• Retire any promotion that rewards a review, and rewrite the ask so it goes to every patient or customer the same way.
• Audit the testimonials on your website. Every one needs a real person, a real experience, and consent in writing. Delete anything you cannot prove.
• Check the review widget on the homepage. Either show everything, or say plainly that it is a selection.
• Stop any gating in your follow-up automation, including the friendly kind that asks how it went before sending the review link.
• Put 21 October in the calendar and have the cleanup finished before then, not started.

A core update has also been rolling out since the middle of last week, so if your rankings have moved, separate the two questions before you change anything. Review cleanup is a compliance job with a date on it. Ranking movement is a different conversation.

None of this makes reviews less valuable. It makes the ordinary, patient work of asking every customer and replying to every review the only version that still runs, which is how we have always set up review programs anyway. For practices, the testimonial and consent side is worth an hour with whoever handles your dental marketing, and the profiles themselves stay part of the same local search routine they always were.