EPG Reputation contact@epgreputation.com

FTC & compliance

Most US businesses are sitting on reviews they're entitled to have removed.

And a smaller number are being sold removals they aren't entitled to, by services that have been operating on the wrong side of a rule that changed in 2024. This page explains both halves of that, and where we stand.

Last reviewed: February 2026 · Not legal advice

1. What the FTC is, for anyone who hasn't dealt with them

The Federal Trade Commission is the United States agency responsible for consumer protection and competition enforcement. Among other things, it polices advertising that misleads consumers. It writes rules, investigates companies, sends warning letters, and brings cases in federal court.

For most small businesses the FTC is invisible right up until it isn't. It doesn't license you, inspect you, or send you renewal notices. You hear from it when something you've done — or something a vendor has done on your behalf — has come to its attention.

2. What changed in 2024

On 14 August 2024 the FTC announced the Rule on the Use of Consumer Reviews and Testimonials. It was published in the Federal Register on 22 August 2024 and took effect on 21 October 2024. It is codified at 16 CFR Part 465.

Before this rule, the FTC could act against deceptive review practices but had limited ability to seek money for it. The rule changed that. It sets out specific prohibited practices and allows courts to impose civil penalties for knowing violations. The maximum penalty is adjusted annually for inflation; it was $51,744 per violation when the rule took effect and has since risen above $53,000.

The rule covers six areas:

Practice What's prohibited
Fake or false reviews Writing, selling, buying, or spreading reviews from people who never used the product or service, or that misrepresent their experience.
Buying sentiment Paying or incentivising anyone to write a review expressing a particular view — positive or negative.
Insider reviews Reviews from employees, owners, or their immediate family without a clear disclosure of the relationship.
Company-controlled review sites Running a supposedly independent review site about your own products.
Review suppression Using unfounded legal threats, physical threats, intimidation, or false accusations to stop or remove a negative review. Also misrepresenting that the reviews displayed are all of them when negative ones have been held back.
Fake social proof Buying or selling bot followers, views, or similar indicators of influence.

3. The part that catches removal services

The fifth item is the one that matters here. Section 465.7 of the rule addresses review suppression, and it reaches conduct that a lot of reputation companies had been treating as routine: leaning on reviewers with legal threats that wouldn't survive contact with a court, accusing a real customer of being fake in order to get a review pulled, or pressuring someone into taking down a complaint they were entitled to make.

Two features of the rule are worth understanding before you hire anyone in this market.

It reaches the vendor as well as the business

FTC staff guidance on the rule states plainly that service providers and intermediaries are not immune from liability. A removal service is not a shield. If the method used on your behalf is prohibited conduct, both the service and the business that engaged it are exposed.

Intent is not the test

You do not have to know that a vendor's method was improper for the underlying conduct to be a problem. This is why "I just paid someone to handle it" is a weak position, and why the method matters more than the outcome when you're choosing who to work with.

The practical consequence

A service that will remove any review you point at is not offering you a shortcut. It is performing conduct in your name, on your Google profile, that is attributable to your business. The removal is the product you can see. The exposure is the part you can't.

4. What happened in 2025

For the first year the rule sat on the books without visible enforcement, which a lot of the industry read as permission. In December 2025 the FTC sent warning letters to ten companies over possible violations of the rule. The letters were based on consumer complaints and information the companies themselves had provided. They were not findings of wrongdoing — they reminded the recipients of their obligations and warned that violations can lead to a federal lawsuit and civil penalties.

Warning letters are usually a precursor rather than an endpoint. The reasonable reading is that the quiet period is over.

Separately, Google has been tightening its own enforcement. Profiles found to have been involved in fake review activity can now carry a public warning banner telling visitors that fake reviews were removed — which is a considerably worse outcome than the review you were trying to get rid of.

5. The right most businesses don't know they have

Here is the part that gets lost in all of the above, and it is the reason this page exists.

Everything the FTC rule prohibits concerns genuine reviews — real feedback from real customers, which you are not entitled to remove and which no legitimate service should offer to remove for you.

It says nothing about reviews from people who were never your customers. Those are a different category entirely. Google's own content policies prohibit them, and Google removes them when a case is properly made. Reporting one is not suppression. It is asking a platform to enforce a rule it already published.

In our experience most owners do not know that the following are removable at all:

  • A review from someone with no booking, invoice, appointment, or file anywhere in your records.
  • A review from a former employee, written as though they were a customer.
  • A review from a competitor, or from an account whose wider posting history shows an interest in your rating rather than your service.
  • A cluster of one-star ratings that arrived in a few days, often with no text, often from accounts created around the same time.
  • A one-star rating attached to a demand for payment to take it down.
  • A review describing a real experience at a different business — a similarly named one, a former occupant of your address, or the wrong branch.
  • A review whose content is a personal attack on a named member of staff, harassment, or the personal information of an employee or another customer.

Owners leave these up because they've tried the report button, been declined, and concluded the review is permanent. The report button submits a category selection into automated assessment with almost nothing attached. A declined report is not a ruling on the merits. It usually means nobody ever saw the evidence, because no evidence was ever submitted.

Put simply

The rule that stops a service removing your customers' honest complaints is the same rule that leaves reviews from non-customers entirely available to you. Those two categories get treated as one thing in most conversations about this, and they are not one thing.

6. Where we draw the line

We take cases where we can show the reviewer was not a customer, or where the content itself breaches a policy Google publishes. That's the whole scope of what we do.

These are our standing commitments, and we'll hold to them in writing:

  • We file only under a named Google policy ground, through Google's own reporting and appeal channels.
  • We do not contact reviewers. No approaches, no offers, no threats, no legal letters.
  • We do not use fake accounts, mass reporting, false claims of impersonation, or any form of manipulation. Those are the practices our clients come to us about.
  • We do not post, buy, or arrange positive reviews for any client, in any form.
  • We decline cases where the evidence isn't there, and we say so rather than take a fee for filing something we expect to fail.
  • We will not accept a case aimed at a genuine customer's honest complaint, regardless of how the request is framed or what is offered.

That last commitment costs us work. We think it is the only version of this service worth selling, and after October 2024 it is also the only version that doesn't hand the client a problem larger than the one they came in with.

We are not lawyers and this is not legal advice. Nothing here creates an attorney–client relationship, and no page on this site should be relied on as a statement of your obligations. If your situation involves defamation, an employment dispute, or an active legal matter, speak to a lawyer licensed in your state. We're happy to work alongside one.

7. Questions we get asked about this

Does hiring you create any FTC exposure for my business?

Not on the basis of what we do. We report reviews to Google under Google's published policies, using evidence. We don't contact reviewers, threaten anyone, or make claims we can't support. If a case ever required something outside that, we'd decline it rather than do it and tell you afterwards.

Are you FTC certified or approved?

No, and neither is anyone else — the FTC doesn't certify or approve companies in this market. Any service telling you it is FTC approved is telling you something that doesn't exist. What we can do is describe our method in full and let you judge it, which is what this page is.

A real customer wrote something exaggerated and unfair. Can you help?

Not by removing it. If they were a customer and they're describing their own experience, that's protected opinion however unfair it feels, and a service willing to remove it is offering you a problem. What genuinely works there is a measured public reply and more recent reviews. We'll tell you that on the audit at no charge rather than take the case.

Does any of this apply outside the United States?

The FTC rule is US law and applies to conduct affecting US consumers. Other markets have their own frameworks — the UK's regime under the Digital Markets, Competition and Consumers Act and various EU rules cover similar ground. Google's content policies, which are what we actually file under, are global.

How do I find out which of my reviews fall on which side?

Send us a link to your Google listing. We'll go through it and reply within one business day telling you which reviews we think are removable, which are borderline, and which are genuine feedback. There's no charge and no obligation to go further.