How to build review volume and recency without breaching advertising rules or the FTC’s testimonial rule.
Written for Client-facing firms in regulated and semi-regulated sectors where reviews influence selection.
The bottleneck
Reviews decay. A five-star average built three years ago reads as a firm that stopped serving clients, and recency weighs heavily in both local ranking and human judgement. Most firms treat review collection as an occasional campaign, which produces a cluster of reviews with a date stamp that ages together.
The compliance dimension is real and frequently mishandled. Incentivised reviews, insider reviews without disclosure and selective suppression are all specifically prohibited, and enforcement is now active.
The FTC’s Rule on the Use of Consumer Reviews and Testimonials has been in force since 21 October 2024, with civil penalties of up to $53,088 per violation. In December 2025 the FTC issued warning letters to ten companies under it. The rule covers fake and insider reviews, incentives conditioned on sentiment, and review suppression.Federal Trade Commission, 16 CFR Part 465; FTC business guidance, December 2025.
Why it happens, five levels down
- Review volume is low and ageing.Why? Nobody asks consistently.
- Asking is nobody’s job.Why? It was never built into the matter or project lifecycle.
- There is no trigger point.Why? Nobody identified the moment a client is most satisfied.
- Client experience is not mapped.Why? Delivery and marketing operate separately.
- Reputation has no owner in the delivery process.Root cause. It is treated as marketing’s job and marketing is not in the room.
The diagnostic
Run this before planning any work. It tells you whether this is your constraint or whether something else is.
- Check the date of your most recent review on each platform.
- Confirm business details are identical and current across every profile.
- Check whether unfavourable reviews have been responded to, and how.
- Identify the moment in your delivery when a client is most satisfied. That is the ask point.
- Review your request process against the FTC rule and your own regulator’s advertising rules.
- Check whether anyone has ever offered an incentive for a review. If so, stop today.
The build sequence
| Stage | Work | Timing |
|---|---|---|
| Correct | Fix names, addresses, categories and hours on every profile. | Week 1 |
| Define | Identify the trigger moment and who makes the ask. | Week 1 |
| Ask | Compliant request, no incentive, no sentiment condition, simple process. | Ongoing |
| Respond | Reply to everything, professionally, especially the critical ones. | Ongoing |
| Monitor | Track volume, rating and recency monthly. | Ongoing |
KPI watchlist
| Metric | Source | Read it as |
|---|---|---|
| Reviews per month | Platform dashboards | Whether the process is running |
| Recency of most recent review | Manual check | What prospects actually judge |
| Response rate to reviews | Platform dashboards | Whether you look present |
| Rating trend | Platform dashboards | Service quality signal |
Record a baseline and a date range for each before any work begins. Reconstructing a baseline afterwards is usually impossible.
Four ways this goes wrong
- Incentivising reviews in any form conditioned on sentiment. This is specifically prohibited.
- Staff or family reviews without disclosure of the connection.
- Suppressing or filtering unfavourable reviews.
- Running a one-off campaign and letting the dates age together.
Check your process against the rule
Most review programmes were designed before October 2024 and have not been reviewed since.
