Reviews, testimonials and fake engagement

Reviews, testimonials, star ratings and follower counts are signals that audiences use to decide whom and what to trust. Because they are valuable, they are also manipulated: brands buy fake reviews, offer rewards only for positive ones, suppress negative ratings and post testimonials from people who never used the product, while some creators buy followers, likes and views to look more influential than they are. This lesson explains the rules on honest endorsements and testimonials, the specific prohibitions on fake reviews and fake engagement in each country, and how creators can protect themselves when brands ask for reviews or when they evaluate other creators.

Honest endorsement: the starting point

In both countries the foundation is the same. An endorsement or testimonial must reflect the honest opinion and genuine experience of the person giving it. That principle has several practical consequences.

• If you say you use a product, you must actually use it, and for a claim about ongoing use, you must still be using it when the endorsement runs.
• You cannot describe results you did not get, or present a brand's script as your own experience unless it matches what happened.
• You cannot claim expertise you do not have. A creator presented as a dentist, dietitian or financial expert must have that expertise and must have actually evaluated the product with it.
• A testimonial that describes extraordinary results implies they are typical unless the ad clearly says otherwise, and a disclaimer such as "results not typical" may not be enough to correct that impression.
• A brand cannot use an old endorsement once it no longer reflects the endorser's views, or once the product has changed in a way that matters.

Testimonials, scripts and brand edits

Brands often supply talking points or scripts. That is normal and lawful, provided the final content reflects the creator's genuine experience and opinion. Problems arise when the script includes claims the creator cannot honestly make, such as "it cleared my acne in a week" when it did not, or when the brand edits the creator's words in a way that changes their meaning. A creator should push back on any script line that is not true for them and should not allow a brand to post edited versions of their content that misrepresent what they said.

The US Consumer Reviews and Testimonials Rule

In the United States, the FTC's Trade Regulation Rule on the Use of Consumer Reviews and Testimonials, 16 CFR Part 465, took effect on October 21, 2024. Unlike the Endorsement Guides, it is a binding rule, so violations can bring civil penalties, which were up to $53,088 per violation in 2025 and remain at that level in 2026. In December 2025 the FTC sent its first warning letters under the rule to about a dozen companies, signaling a move from education to enforcement.

The rule prohibits six categories of conduct, summarized below, and the Endorsement Guides continue to apply alongside it. In addition, the Consumer Review Fairness Act of 2016 makes contract clauses that bar or penalize customers for posting honest reviews void and unlawful.

In the United States, section 465.4 prohibits offering compensation or incentives conditioned, expressly or by implication, on writing a review with a particular sentiment. Disclosing a sentiment-conditioned incentive does not cure the violation. Unconditioned incentives remain lawful but should be disclosed under the Endorsement Guides.

Review suppression and gating

Review gating means asking customers whether they are satisfied and then inviting only satisfied ones to post public reviews, or filtering out negative reviews before display. Suppressing negative reviews, whether by threats, by contract terms or by quietly hiding them, makes the remaining reviews misleading.

In the United States, the FTC's 2022 case against the online retailer Fashion Nova, which used a system that held back reviews below four stars from its website, led to a $4.2 million payment. Section 465.7 of the rule now prohibits review suppression through unjustified legal threats, intimidation or false accusations, and misrepresenting that displayed reviews represent all or most reviews when negative ones were suppressed.

Fake followers, views and engagement

Some creators buy followers, likes, comments or views, or join "engagement pods" where members agree to like and comment on each other's posts. Bought metrics mislead brands that pay based on audience size and engagement, and they mislead audiences that see popularity as social proof. They also usually break platform rules, which prohibit inauthentic engagement and can lead to removed accounts.

In the United States, section 465.8 prohibits selling, and buying for commercial purposes, fake indicators of social media influence, such as followers, views or likes generated by bots or accounts that do not reflect real individuals or real activity, when the buyer knew or should have known they were fake. The FTC's 2019 settlement with Devumi, a company that sold fake followers and views, showed the FTC's view that selling fake influence is deceptive.

Detecting inflated metrics

Brands and creators evaluating other creators use simple checks to spot inflated metrics. None is conclusive on its own, but together they flag accounts for closer review.

• Engagement that is far below the norm for accounts of that size, suggesting many inactive followers.
• Sudden spikes in followers without a viral post or press coverage to explain them.
• Comments that are generic, repetitive or unrelated to the post.
• Audience locations that do not match the creator's language or content.
• Views far higher than likes or comments, or likes arriving in unnatural bursts.

What creators should do

• Never buy followers, likes, views or comments, and leave engagement pods that create artificial engagement.
• Present metrics honestly in media kits, using platform analytics and stating dates, and correct mistakes quickly.
• Refuse requests to post fake reviews, reviews of products you have not used, or reviews on behalf of others.
• Disclose incentives when you review products on retail sites as well as on social media.
• Do not promote review-gating or sentiment-conditioned offers to your audience.
• If you employ others, train staff and family who post about your products to disclose the connection.

Reviews on retailer and marketplace sites

Creators are sometimes asked to post reviews on retailer or marketplace sites as part of a deal, or receive free products through programs that invite reviews. The same honesty and disclosure principles apply there as on social media, with some practical differences.

• Retail reviews are read by shoppers comparing products, often without any knowledge of who the reviewer is, so an undisclosed connection is especially misleading.
• Many retailers have their own rules: some prohibit reviews in exchange for free products except through their own programs, and some label incentivized reviews automatically.
• A review should describe your real experience with the product, including drawbacks, and should be posted only after you have used it long enough to form a view.
• Do not post several reviews under different names, ask friends to post reviews for products they have not used or copy a brand's suggested review text.

A simple first line such as "I received this product free from the brand in exchange for an honest review" meets the disclosure standard on most sites. If a brand asks for a review only if your experience is positive, or offers a bonus for a high rating, decline: that is the sentiment-conditioned incentive this lesson warned about.

Testimonials the brand reuses

Brands often ask to reuse a creator's content or quotes in their own ads, websites and packaging. Once a testimonial moves into the brand's own advertising, it must still reflect the creator's current, genuine opinion. Creators should limit reuse in their contracts by time and place, ask to be told when quotes are used and ask the brand to stop using a testimonial if their view changes or the product is reformulated.