In August 2024, I wrote about the Federal Trade Commission's then-new Consumer Review Rule (Adieu, Fake Revie(u)w), which is designed to preserve the authenticity of online reviews and prohibit companies from suppressing honest consumer feedback. Just over a year later, the FTC has taken its first public enforcement step by warning 10 companies about potential violations of this important rule (see FTC Announcement, Dec. 22, 2025).

What the FTC announced—and why it matters

• The FTC’s announcement states that staff issued warning letters to 10 unnamed companies for possible violations of the agency’s Consumer Review Rule. The Commission also released the template warning letter that accompanied those notices.

• The template letter communicates that FTC staff has information suggesting the recipient may be engaged in practices covered by the Consumer Review Rule and reminds recipients of their obligations to comply. It urges companies to evaluate their practices in light of the rule and indicates that noncompliance could lead to enforcement.

• The takeaway is straightforward: The rule is not merely aspirational. The FTC is proactively investigating, notifying companies when it sees potential problems and setting expectations for prompt compliance.

Practical steps for brands and marketers now

Given the FTC’s move to issue warning letters, brands should prioritize a documented, defensible compliance program around consumer reviews and testimonials. Practical steps include:

1. Map your review and testimonial ecosystem

• Inventory where and how you solicit, collect, host, moderate and syndicate consumer reviews and testimonials (website, marketplaces, social platforms, retail partners).

• Identify internal teams and outside vendors (review solicitation services, UGC platforms, reputation management firms) that touch reviews.

2. Tighten policies and controls

• Adopt (or update) written policies that prohibit creating, procuring or facilitating fake or misleading reviews or endorsements, and that require transparency around any material connections.

• Implement a clear, viewpoint-neutral moderation policy. Apply it consistently, document decisions and avoid practices that could be perceived as suppressing legitimate negative feedback.

3. Train and monitor

• Train marketing, social, customer service and community management teams on the rule’s requirements and the company’s policies.

• Establish periodic monitoring and spot checks (including audits of vendor activities) to confirm that solicitation, moderation and publishing practices align with policy.

4. Strengthen vendor oversight

• Revisit contracts with any vendors involved in reviews or endorsements. Require compliance with the Consumer Review Rule and applicable advertising/endorsement standards, audit rights and termination for noncompliance.

• Conduct diligence on how vendors source, filter and display reviews and what incentives (if any) they use.

5. Calibrate incentives and disclosures

• If you offer discounts, samples, loyalty points or other benefits tied to reviews or testimonials, ensure programs do not favor only positive reviews and that any material connections are clearly disclosed to consumers.

• Maintain templates and guidance for disclosures in solicited reviews and testimonials.

6. Preserve records

• Keep contemporaneous documentation of solicitation methods, moderation decisions, vendor instructions and compliance training. Robust records can be critical in responding to agency inquiries.

7. Prepare a rapid response plan

• Designate a cross-functional team (legal, marketing, customer experience) to triage any notice from the FTC. Establish an internal process to pause questionable practices quickly, assess exposure and implement corrective action.

Bottom line

In my August 2024 analysis, I emphasized that the Consumer Review Rule would bring sharper lines and higher stakes for how companies handle consumer feedback. The FTC’s December 2025 warning letters are the clearest signal yet that the agency is actively looking for noncompliance and is prepared to escalate if needed. Now is the time to pressure-test your review and testimonial practices—both internally and across your vendor network—to ensure they reflect the spirit and letter of the rule.