Is it legal to offer a discount for a review? FTC rule vs Google ban

Mostly no, and the version that is legal still costs you the reviews. Under the FTC’s Consumer Reviews and Testimonials Rule, in force since October 21, 2024, offering a discount, freebie, or anything else of value in exchange for a positive review is illegal in the United States, with civil penalties of up to $53,088 per violation. Not per campaign. Per violation, which the FTC can read as per review. A discount for any honest review, one star or five, with the deal disclosed, is outside the rule. But Google bans review incentives of every kind, Yelp does too, and both enforce by deleting reviews. So the FTC-legal discount and the FTC-illegal discount end in the same place: a thinner profile with a flag on it.

That’s the whole answer. The rest of this post covers why so much advice online still gets it wrong, what enforcement looks like as the rule turns two, where exactly the FTC draws its line for incentives that aren’t tied to sentiment, and what to do instead.

Why you still see “incentives are fine if you disclose” advice

Before October 2024, incentivized reviews lived under the FTC’s Endorsement Guides: guidance, not a rule, enforceable only through slow case-by-case actions with no automatic penalty attached. Under that regime, “disclose the incentive and you’re probably fine” was defensible advice, and thousands of marketing posts from 2015-2023 still say it. They’re fossils. The Guides are still in force and still require the disclosure, but the 2024 rule stacked a trade regulation with civil penalties on top of them, and it specifically prohibits any incentive conditioned, expressly or by implication, on the review expressing a particular sentiment. Disclosure doesn’t cure that. A disclosed bribe is still a bribe.

And this stopped being theoretical in year one. On December 22, 2025, the FTC sent warning letters to ten companies, its first sweep under the rule, and one of the practices the letters called out by name was offering incentives only for positive reviews. The recipients were anonymous at first; the FTC later posted the letters themselves. In January 2026 it settled with Growth Cave, the first case to allege a violation of the rule: a $48.6 million judgment, largely suspended for inability to pay, plus a permanent ban from selling business opportunities. Growth Cave was about undisclosed employee testimonials rather than discounts, which tells you where the FTC is starting: the egregious end of the pool. The penalty figure hasn’t moved either. Federal fines normally get an inflation bump each January, but the autumn 2025 shutdown meant no October price index, the 2026 adjustment was cancelled, and the FTC confirmed in September 2026 that $53,088 stands. We keep the running tally in our post on the rule’s enforcement record.

What it looks like when a business gets this wrong

Bluebonnet Med Spa in Round Rock, Texas, ran a checkout promotion for most of 2025: leave us a 5-star Google review before you leave and get $15 off today’s visit. The receptionist would watch the review post, then apply the discount. It worked, in the way these things work: 60-odd reviews in five months, rating pinned at 4.9.

Then a customer mentioned the deal in the review itself: “Great facial, and you get $15 off for leaving 5 stars!” Google’s detection systems treat incentivized reviews as fake engagement, and once a profile is implicated they don’t just remove one review. They re-evaluate the pattern. Bluebonnet lost 41 reviews in a single sweep, the rating dropped to 4.2 on the remaining organic base, and new reviews took weeks to post while the profile sat under restrictions. Nobody fined them (FTC enforcement so far has aimed at bigger fish), but the platform consequence alone erased the asset the discounts had bought, plus roughly $950 in discounts out of pocket.

That’s the typical failure mode: not a federal penalty, but a platform purge that takes your legitimate reviews down with the bought ones. And you no longer need a chatty customer to trigger it. Since late 2025 the Google Maps app has been putting a direct question to some reviewers when they visit a business: “Does this business offer rewards in exchange for reviews?” Yes, no, or not sure. Google hasn’t formally announced the prompt and it isn’t showing to everyone yet, but the direction is plain. Google has started asking your customers whether you paid them.

“But what if the incentive isn’t tied to a positive review?”

The clever-sounding workaround: offer the discount for any honest review, five stars or one. Here the FTC is clearer than most commentary admits. Its own Q&A on the rule says the rule does not prohibit incentives for reviews as long as there is no express or implied requirement that the review express a particular sentiment, and the incentive section binds the business offering the deal, not the customer taking it. Two conditions ride along. First, the incentive is a material connection under the Endorsement Guides, so the reviewer has to disclose it and you have to tell them to; an undisclosed incentivized review is a plain FTC Act problem even when the rule itself is satisfied. Second, the condition can be implicit. If the coupon comes with “we’d love five stars,” or the sign at the register shows a five-star example as the one to copy, the sentiment condition is there whether or not anyone wrote it down.

But here’s the part the legal analysis misses: the platforms already decided this for you. Google’s contribution policy bans incentives “such as payment, discounts, free goods and/or services” in exchange for posting any review, or for revising or removing one, and files anything “paid for, directly or in kind” under fake engagement, the category that triggered Bluebonnet’s profile-wide re-evaluation. Sentiment-neutral or not. The compliant way to ask inside those review policies is its own post. Yelp goes further and discourages asking for reviews at all; its guidance to owners is blunt (“don’t ever offer freebies, discounts, or payment in exchange for reviews”), and a business caught doing it gets a Consumer Alert stamped on its Yelp page for 90 days, a public banner telling prospects the reviews may have been bought. Amazon bans compensated reviews outside its own Vine program. So even a lawyer-approved, disclosed, any-star incentive gets your reviews removed and your profile flagged. Legal exposure is the smaller of your two problems.

What to do instead

Ask everyone, at the right moment, with zero strings. That’s the entire compliant playbook, and it outperforms incentives anyway: BrightLocal’s 2026 Local Consumer Review Survey found 83% of customers who are asked to leave a review do so. You don’t need to buy what four out of five customers will give you for free. You need a consistent ask (a text with a direct link at job completion beats an email a week later) and responses that make reviewing feel acknowledged. Responding well to the five-stars you already have is the multiplier most businesses skip; there’s a set of positive-review response templates if you want wording that doesn’t read like a form letter.

If a card, text or sign of yours still has strings attached, paste it into our free review request audit, which flags the rules that wording breaks, with a fix and a dated source for each.

The broader strategy, what to say when the reviews aren’t five stars, is covered in the negative review response playbook.

One more trap: the “review us” contest

Raffles and giveaways (“leave a review, get entered to win a gift card”) feel softer than discounts but sit in exactly the same bucket: an incentive for a review. Google’s ban covers incentives in any form, cash or in kind, and a sweepstakes entry is a thing of value. On the FTC side, the entry is a material connection the reviewer has to disclose, and the moment eligibility depends on the review being positive, it’s the same violation wearing a party hat.

The rule of thumb that survives every edge case: money can flow to customers, and reviews can flow from customers, but the two can never be connected by an “if.”