FTC Guidelines for Incentivized Reviews: What You Need to Know

You want more G2 reviews. Your boss wants more G2 reviews. Everyone wants more G2 reviews.

So you decide to offer a $25 gift card to customers who leave one.

Is that legal? Is it ethical? Will G2 remove the reviews?

The answers aren't as simple as you'd hope. This guide breaks down exactly what the FTC requires, what review platforms allow, and how to run incentivized review campaigns without getting your company in trouble.

Why FTC Guidelines Matter for B2B Reviews

The Federal Trade Commission (FTC) has clear rules about endorsements and testimonials. These rules apply to B2B companies just as much as consumer brands.

The Stakes Are Real

FTC enforcement actions have resulted in:

• Fines up to $50,000 per violation for companies that fail to disclose material connections
• Required corrective advertising that damages brand reputation
• Removal of reviews from platforms when violations are discovered

In 2023, the FTC updated its Endorsement Guides for the first time since 2009, adding specific provisions about reviews and incentives. Ignorance is no longer a defense.

What Counts as an Incentive?

According to the FTC, an incentive is anything of value provided to a reviewer:

If a reasonable person would consider it valuable enough to influence their decision to leave a review, it's an incentive that must be disclosed.

The Core FTC Requirements

Requirement 1: Clear and Conspicuous Disclosure

If you provide any incentive for a review, the reviewer must disclose it. The disclosure must be:

Clear: Easy to understand, not buried in legalese.

Conspicuous: Visible and noticeable, not hidden in small print.

Close to the claim: Placed near the review content itself.

What "Clear and Conspicuous" Means in Practice

The FTC is specific about what doesn't work:

• Disclosures that require scrolling to see
• Disclosures hidden behind "more" links
• Disclosures in fine print or light text
• Disclosures only in terms and conditions

Good disclosure example:

"I received a $25 gift card for writing this review. My opinions are my own."

Bad disclosure example:

"Disclosure: See terms." (with terms buried elsewhere)

Requirement 2: Honest Opinions Only

Incentives can be offered for reviews, but you cannot:

• Require positive reviews
• Condition the incentive on a certain star rating
• Reject or withhold incentives for negative reviews
• Edit or filter reviews based on sentiment

The FTC calls this "review gating" and it's explicitly prohibited.

Requirement 3: You're Responsible Too

Here's what catches many B2B companies off guard: you're liable for your reviewers' disclosures.

If a customer leaves an incentivized review without proper disclosure, your company can be held responsible. The FTC expects you to:

• Provide clear instructions on disclosure requirements
• Monitor reviews for compliance
• Follow up when disclosures are missing
• Have systems to ensure ongoing compliance

What Each Review Platform Requires

Beyond FTC requirements, each review platform has its own policies. Here's what the major B2B platforms allow:

G2

G2 permits incentivized reviews with conditions:

G2's disclosure approach: G2 marks reviews as "incentivized" in their system. However, you should still instruct reviewers to include their own disclosure in the review text for FTC compliance.

Capterra

Capterra's policies mirror G2's:

• Incentives must be offered to all reviewers regardless of rating
• Incentives must be modest (typically under $50)
• You cannot require specific content or ratings
• Capterra flags incentivized reviews in their system

TrustRadius

TrustRadius is stricter:

• They discourage direct incentives for reviews
• If incentives are offered, they must be disclosed
• TrustRadius has their own reward program and prefers reviews through that channel
• Reviews are verified through LinkedIn authentication

Google Business Reviews

Google's policy is the most restrictive for B2B:

• Incentivized reviews are technically against Google's guidelines
• Google relies on organic reviews
• Offering incentives risks review removal or profile suspension

Recommendation: Don't offer incentives for Google reviews. Focus your incentive program on G2 and Capterra.

Building a Compliant Review Program

Here's a step-by-step framework for running an FTC-compliant incentivized review program. If you want a time-boxed approach, our guide on running a review campaign in 7 days walks through a compliant sprint structure you can follow immediately.

Step 1: Choose Appropriate Incentives

Keep incentives modest to avoid the appearance of "buying" reviews:

For most B2B review programs, the $25-50 range is the sweet spot: enough to motivate action, not enough to seem like you're buying opinions.

Step 2: Draft Your Request Language

Your review request should make clear that:

1. Honest feedback is expected
2. An incentive is being offered
3. Disclosure is required

Template for compliant review request:

Hi [Name],

Would you be willing to share your honest experience with [Product] on G2?

As a thank-you for taking the time (typically 5-10 minutes), we're offering a $25 Amazon gift card.

Important: Please include a note in your review that you received an incentive. Something like "I received a gift card for writing this review" works perfectly.

Your honest feedback--positive or constructive--helps other buyers make informed decisions.

[Link to G2 review page]

Step 3: Provide Disclosure Templates

Make it easy for reviewers to comply. Include copy-paste disclosure text:

Option 1 (Brief):

"Disclosure: I received a gift card for this review."

Option 2 (Standard):

"I received a $25 gift card for writing this review. My opinions are entirely my own."

Option 3 (Detailed):

"Full disclosure: [Company] offered me a $25 Amazon gift card for sharing my experience on G2. This didn't influence my review--I've been using the product for [X months] and these are my honest opinions."

Step 4: Monitor for Compliance

Set up a system to check that disclosures are included:

1. Review alert: Get notified when new reviews are posted
2. Disclosure check: Verify each incentivized review includes disclosure
3. Follow-up: Contact reviewers who forgot to disclose
4. Documentation: Keep records of your compliance efforts

Step 5: Handle Missing Disclosures

If a reviewer forgets the disclosure:

1. Reach out promptly (within 48 hours)
2. Politely request an edit to add the disclosure
3. Provide the exact text they can add
4. Document your outreach in case of audit

Most platforms allow reviewers to edit their reviews, making it easy to add the disclosure after the fact.

Common Mistakes to Avoid

Mistake 1: Review Gating

What it is: Only asking satisfied customers for reviews, or filtering out negative reviews.

Why it's wrong: The FTC explicitly prohibits suppressing negative reviews while publishing positive ones.

How to avoid it: Ask all customers for reviews, not just those with high NPS scores. You can target engaged users, but not based on sentiment.

Mistake 2: Conditional Incentives

What it is: "Leave a 5-star review and get a $50 gift card."

Why it's wrong: Conditioning rewards on positive ratings is deceptive.

How to avoid it: Offer the same incentive for any honest review, regardless of rating.

Mistake 3: Hidden Disclosures

What it is: Putting disclosure requirements in your terms of service, assuming that covers it.

Why it's wrong: Disclosures must be in the review itself, not referenced elsewhere.

How to avoid it: Require disclosure text directly in the review body.

Mistake 4: Fake Urgency

What it is: "Only the first 20 reviewers get the gift card!"

Why it's cautionary: While not explicitly illegal, artificial urgency could pressure customers into hasty reviews that don't reflect genuine opinions.

Better approach: Set a campaign deadline, but give adequate time (2+ weeks) for thoughtful reviews.

Mistake 5: Employee Reviews

What it is: Having employees leave reviews without disclosure.

Why it's wrong: Material connection (employment) must be disclosed.

How to avoid it: If employees review, they must clearly state "I work at [Company]."

Disclosure Checklist

Before launching your incentivized review campaign, verify:

• Incentive value is modest ($25-50 range)
• Review request clearly states an incentive is offered
• Request emphasizes honest feedback (positive or negative)
• Disclosure templates are provided
• Monitoring system is in place
• Follow-up process for missing disclosures is documented
• Team is trained on compliance requirements
• Records are maintained for potential audit

What About Non-Monetary Incentives?

Some companies try to avoid disclosure requirements by offering "non-monetary" incentives. Be careful--most of these still require disclosure:

The threshold is low: if a reasonable customer would consider it valuable enough to influence their decision to leave a review, it needs disclosure.

The Bottom Line

Running an incentivized review program isn't complicated, but it does require attention to compliance:

1. Keep incentives modest ($25-50 range)
2. Offer to all customers regardless of sentiment
3. Require clear disclosure in the review itself
4. Monitor compliance and follow up on missing disclosures
5. Document everything in case of questions

Done right, incentivized reviews are a legitimate way to encourage customers to share feedback. The key is transparency: be upfront about the incentive, require disclosure, and never condition rewards on positive ratings.

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