FTC Cranks Up Enforcement on Consumer Reviews — Here’s What Marketplaces and Platforms Need to Know

If you run a marketplace or digital platform, you already know consumer reviews aren’t just “nice to have” — they’re mission critical. Reviews drive discovery, build trust, and shape purchase decisions. But with that power comes risk. The Federal Trade Commission (FTC) is now signaling it intends to enforce its Consumer Review Rule in earnest — and that’s a big deal for every platform operator.

On December 22, 2025, the FTC sent warning letters to 10 companies, telling them they may be violating the Consumer Review Rule — an enforcement step that should get every marketplace CEO, product leader, and trust-and-safety team’s attention. So what’s happening — and why should you care?

The Consumer Review Rule: A Quick Refresher

The Consumer Review Rule, which took effect in October 2024, was designed to clean up deceptive and unfair practices involving customer reviews and testimonials. At its core, the Rule:

• Bans fake or false consumer reviews — you cannot publish reviews from people who didn’t use the product or misrepresent their experience.

• Outlaws conditioned incentives — you can’t offer rewards only for positive reviews (e.g., bonuses for 5-star ratings).

• Requires disclosure for insider reviews — reviews from employees or closely connected insiders must include clear, conspicuous disclosure of that relationship.

• Limits suppression practices and deceptive use of influence indicators (like fake followers or engagement metrics).

This isn’t regulatory theory — it’s now actionable law, and violations carry serious consequences (including civil penalties of up to $53,088 per violation). 

Why the FTC Is Sending Warning Letters

In this initial enforcement push, the FTC didn’t name the companies it warned, but the language in the letters makes the agency’s priorities very clear: it has reason to believe these companies are engaging in deceptive review practices that violate the Rule.

Examples flagged (in legal commentary) include:

• Compensating employees or insiders to generate positive reviews,

• Publishing reviews from people who don’t clearly disclose they’re connected to the company, and

• Using language in terms or contracts that could suppress critical feedback or penalize negative reviews.

  
  

The letters are warning letters — meaning regulators stopped short of formal enforcement — but they’re a very clear signal that the FTC is watching and ready to escalate.

What This Means for Marketplaces and Platforms

Marketplaces and digital platforms sit at the center of review ecosystems. That gives you influence — but also responsibility. Here’s what I recommend you and your teams prioritize now:

1. Revisit Your Review PoliciesAudit your review collection and display practices:

• Are you offering perks that are tied only to positive reviews?

• Do your terms give customers full freedom to post whatever they genuinely experienced?

• Is your language compliant, clear, and consumer-friendly?

If the answer is anything other than a confident “yes,” it’s time for updates.

2. Clean Up Incentives & RewardsReview incentives are common — but they must be structured carefully. Offering discounts or rewards should not be conditioned on positive feedback. That’s exactly the kind of conduct the FTC is targeting. 

3. Strengthen Transparency Around Insider ReviewsEmployees, executives, and affiliates who post reviews should be clearly flagged. Hidden insider reviews are now a red flag under the Rule. 

4. Educate Your Sellers/PartnersIf your marketplace lets third-party sellers manage their own reviews or incentivize them, you need clear guidance and compliance guardrails. Your platform could be on the hook if bad actors misuse your tools.

5. Don’t Sleep on Technology & Moderation ToolsFake, AI-generated, or spam reviews are more common than ever. Investing in robust detection and moderation technology isn’t just good practice — it’s key risk management.

Why This Matters Now

The FTC’s warning letters are more than an isolated news item — they’re a practical enforcement signal that the agency is ready to hold companies accountable under the Consumer Review Rule. For marketplaces and platforms, this raises the bar on trust, transparency, and authenticity. It’s also part of a broader regulatory environment where consumer protection agencies are increasingly focused on online experience integrity. Ignoring this curve isn’t just risky — it’s strategic negligence.

Take this head’s-up seriously. Start with a review of your policies, terms, incentives, and moderation workflows. Then, educate your internal teams and external sellers about the stakes. I also recommend checking out the Coalition for Trusted Reviews, as they are the foremost industry group focused on safeguarding authentic and reliable reviews globally. In a world where reviews are central to consumer decision-making, getting this right protects your users and your business.