Using customer testimonials without breaking the rules

A testimonial is safe to use when it comes from a real customer, says what they actually think, does not promise results most people will not get, and discloses any connection a reader would not expect. Those 4 tests cover most of what US rules ask of a small business.

This guide explains the federal rules on testimonials and reviews in plain terms. It is general information, not legal advice. If you work in a regulated field, such as a med spa, or you make claims about results, have a lawyer review your marketing.

The two sets of rules

The Federal Trade Commission has long published its Endorsement Guides, which explain how the ban on deceptive advertising applies to endorsements and testimonials.^[1] In 2024 it added a separate rule on consumer reviews and testimonials, which took effect on October 21, 2024, and lets courts impose civil penalties for knowing violations.^[2]

The FTC draws a line between the two terms. A consumer review is an evaluation posted on a site or page built to collect and show reviews. A testimonial is an advertising message that people are likely to believe reflects a customer's own opinion or experience.^[3] The quote on your homepage is a testimonial. The post on your Google profile is a review.

This is not a dormant rule. In December 2025, FTC staff sent warning letters to 10 companies about possible violations, and said that violations can lead to a federal lawsuit and civil penalties of up to $53,088 per violation.^[4]

Use only real customers and real words

The review rule makes it a violation for a business to write or create a testimonial that misrepresents that the person exists, that they used the service, or what their experience was.^[5] A business also may not spread testimonials it knew or should have known were false in those ways.^[5]

The Endorsement Guides add that an endorsement must reflect the honest opinion or experience of the person giving it.^[6] If the testimonial says the person uses your service, they must have been a real customer when they gave it.^[6] In practice that rules out invented quotes, "composite" customers, and staff posing as clients.

Edit for length, not for meaning

You do not have to use a customer's exact wording unless you say you are quoting them. You cannot present a testimonial out of context, or reword it in a way that distorts what the person thinks.^[6]

• Fine: trimming a long email to its 2 key sentences, fixing a typo, or using a first name and town with permission.
• Not fine: cutting "the results were fine but the booking was a mess" down to "the results were fine," or merging praise from 2 customers into one quote.

Get the customer's permission in writing before you publish their name, photo, or words, and keep it with their record.

Watch claims about results

Results claims carry the most risk for coaches and med spas. Under the Endorsement Guides, a business must have adequate evidence for the claims a testimonial makes, stated or implied.^[7] If a testimonial suggests that the person's experience is typical, the business should have evidence for that. Otherwise the ad must clearly disclose the results people can generally expect.^[7]

A coach quoting a client who "doubled revenue in 3 months" is implying others can do the same. A med spa showing one dramatic before-and-after photo is doing the same thing with a picture. A vague line such as "results not typical" does not tell readers what to expect. The guides ask for a clear statement of the results people can generally expect.^[7]

The FTC's Q&A notes that picking particularly positive reviews for your marketing is not banned by the review rule, but warns that using reviews that are not representative could be deceptive under the FTC Act.^[3]

Disclose connections readers would not expect

If there is a connection between the person and your business that could affect how much weight a reader gives the testimonial, and readers would not expect it, it must be disclosed clearly.^[8] The guides list business, family, and personal relationships, payment, and free or discounted products or services as examples.^[8]

So a testimonial from your sister, your office manager, or a client who got a free treatment in exchange needs a plain disclosure next to it. The review rule also requires officers and managers to disclose their relationship when they post reviews or testimonials about their own business.^[9]

Ask everyone, and never pay for praise

The review rule bans offering money or other incentives in exchange for reviews that express a particular sentiment, positive or negative.^[10] The FTC's guide for marketers goes further. It advises against asking only the customers you think will leave positive reviews, and says that a review should disclose any incentive even when it was not conditioned on being positive.^[11]

The same guide advises against asking staff, family, or friends for reviews unless they disclose the connection.^[11] The Endorsement Guides also say a business should not procure, suppress, edit, or organize reviews in a way that distorts what customers think.^[7]

The simple habit is to send the same request to every customer after every visit. Our review requests do that by text or email when a job or appointment is marked done, so you are not choosing who gets asked. Our guide to getting more Google reviews covers timing and wording.

Do not hide the bad ones

The review rule bans using groundless legal threats, intimidation, or false public accusations to stop or remove a review.^[12] If your site has a reviews section, you may not suppress reviews because of their rating or negative tone while suggesting that what you show is all or most of what was submitted.^[12]

The rule lists fair reasons to hold a review back, such as abusive or obscene content, other people's personal information, content that is clearly false, or content wholly unrelated to your services.^[12] For a critical review that is real, a calm public reply works better. Our guide on how to respond to negative reviews covers what to say.

A checklist before you publish

1. Confirm the person is a real customer and you have their written permission.
2. Check any edit keeps the original meaning.
3. For results claims, add a clear statement of what customers can generally expect.
4. Disclose any family, staff, or paid connection, and any free service or incentive.
5. Ask every customer for feedback in the same way, not only the happy ones.
6. If your site shows a reviews section, do not filter out the critical ones.

Pinn.Media CRM can show your reviews on your website with a widget that updates as new reviews arrive, and collect short video testimonials from customers. See how a med spa and a coaching practice use them.

Want a review process that asks every customer the same way? Book a walkthrough and we will show you how it runs, or compare plans.