Yes. You can put real customer reviews and testimonials on your own website, and no federal rule stops you. What you cannot do is make them up, hide the bad ones while implying you show them all, or run a quote from your own office manager without saying who he is.
The rule that covers this took effect in 2024
The Federal Trade Commission’s Trade Regulation Rule on the Use of Consumer Reviews and Testimonials sits at 16 CFR Part 465. It was published in the Federal Register on August 22, 2024, at volume 89, pages 68034 to 68079, and took effect on October 21, 2024.
It is short. Part 465 runs to nine numbered sections, and one of those, 465.3, is reserved and blank.
Section 465.2 is the core of it. It bans reviews and testimonials that misrepresent that the reviewer exists, that the reviewer used your business, or what their experience actually was. An honest quote from a real customer breaks none of that.
This is not legal advice. For your own contract, your own site, and your own state, ask an attorney licensed where you work.
A review and a testimonial are not the same thing
Section 465.1 splits them. A consumer review is an evaluation the customer submits, published to a site that collects and displays them. A consumer testimonial is a promotional message that people are likely to believe reflects a real customer’s experience.
The quote on your homepage under a photo of a new water heater is a testimonial. The FTC’s Endorsement Guides, at 16 CFR Part 255, were revised in the Federal Register on July 26, 2023, at volume 88, pages 48092 to 48112. Section 255.1(a) says an endorsement may not carry a claim, said outright or implied, that would be deceptive if you said it yourself. The words are the customer’s. The claim is yours.
That matters when the quote promises a result. “They cut my power bill in half” is a performance claim. Section 255.2(b) says that if you do not have backing that an endorser’s experience is representative of what people generally get, the ad should clearly and conspicuously disclose the generally expected performance.
For a trade, that means picking quotes about the work and the crew, not about savings you cannot support. “On time, cleaned up after himself” is safe ground. “Saved me $4,000” needs numbers behind it.
When you have to say the reviewer works for you
Section 465.5 is the one most contractors trip over. Under 465.5(a), an officer or a manager who writes a review or a testimonial about the business has to disclose that relationship, clearly and conspicuously. The rule lets you skip the disclosure in one case only: a testimonial where the relationship is already clear to the audience. For a review posted on a review site, there is no such let-off.
It runs the other way too. Under 465.5(b), a business may not put out a testimonial from its own officer, manager, employee, or agent without that disclosure, when the relationship is not otherwise clear and the business knew or should have known.
There is a family rule as well. Section 465.5(c) covers an officer or a manager asking relatives or employees for reviews, then letting them run with no disclosure, or telling them not to disclose, and what you may offer anyone in return for a review is a separate question again.
None of that bans the review. You can put your foreman’s mother on the site after you reroofed her house. You just have to label it. And “clear and conspicuous” is defined in 465.1 as easily noticeable, difficult to miss, and easily understandable by ordinary consumers. So the label goes with the quote, in the same size type as the quote.
You can choose your best quotes. You cannot pretend they are all of them
Section 465.7(b) is narrower than people think. It covers reviews shown in a part of your site set up, in whole or in part, to receive and display customer reviews. There, you cannot materially misrepresent that what shows represents most or all of the reviews submitted, when reviews are held back on rating or negative feeling.
A hand-picked testimonial wall is not that. A form on your site that invites reviews, then quietly drops the two-star ones while the page calls itself “our reviews,” is exactly that.
The same section allows taking reviews down, as long as you apply the same standard to every review regardless of sentiment. It names the grounds, among them abusive or obscene content, another person’s private information, content that is clearly false, a review you reasonably believe is fake, and a review with nothing to do with what you sell.
Section 465.7(a) covers the other end. Answering a bad review with a groundless legal threat, a physical threat, intimidation, or a public accusation you know is false, in order to stop it being written or get it taken down, is itself a violation.
The clause to cut out of your own paperwork
Look at your service agreement and the fine print on your quote form. If either tells the customer not to post negative reviews, or charges a fee if they do, that line is already dead.
The Consumer Review Fairness Act, at 15 U.S.C. 45b, came from Public Law 114-258, signed December 14, 2016. It makes such a provision in a form contract void from the inception of the contract, and offering a form contract containing one is unlawful. It also voids a clause that makes the customer hand over intellectual property rights in what they wrote, with one carve-out: a clause taking a non-exclusive license to use the content is allowed.
That carve-out points at the next question, and the FTC rule does not answer it: copying a Google review onto your own site. The rule is about truth, not permission. Your customer wrote those words and took that photo, so who owns them is a copyright question instead. Two other pieces here cover it, on who owns the words on your site and on a letter about a photo you published. The short version is to ask the customer in writing and keep the reply. The terms of whichever platform the review came from are a separate layer, worth reading there. None of that is legal advice either. Contract and copyright questions turn on where you work, so run your paperwork past an attorney licensed in your own state.
Here is the honest limit. All of the above is the text of the rules, nothing more. None of these documents says how hard the FTC comes after a three-truck HVAC company, and anyone who says they know is guessing. For scale only, and again not as legal advice: 16 CFR 1.98(d) sets the maximum civil penalty for a rule violation under section 5(m)(1)(A) of the FTC Act at $53,088, a figure set at 90 FR 5581 on January 17, 2025. That is a ceiling, not a forecast, and it is re-set for inflation, so check the current figure yourself.
What to do this week
Nobody needs to sell you anything to fix this. It is an afternoon with your own site open.
- Go down your testimonials page. For each quote, can you name the customer, the job, and roughly when? If not, take it down.
- Put a plain line on any quote from an officer, a manager, an employee, or a relative. “Dave is my brother” is enough.
- Read the quotes for promises. Swap out anything about savings or speed you cannot support.
- If your site collects reviews through a form and shows only some, say plainly that it is a selection.
- Search your service agreement for the word “disparage.” Delete what you find.
- Email the customers whose reviews you copied across. One line, and save the reply.
If your web company holds the site and will not make those edits, that is a different problem, and a bigger one than your reviews page. Start with who owns your website.